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Employee Information Handbook

HARTFORD | DOWAGIACNEW BUFFALO

Contents

February 1, 2014 i

Contents

Mission Statement ...................................................................................................... 1 Our Vision ..................................................................................................................................1 Our Mission ...............................................................................................................................1 Our Core Values ........................................................................................................................1

Welcome and Introduction ......................................................................................... 2 Pokagon Gaming Authority .......................................................................................................2 Communication ..........................................................................................................................2

Equal Employment Opportunity ................................................................................ 3 At Will Employment ..................................................................................................................3 Employment of Relatives ...........................................................................................................3

Our Expectations of You ........................................................................................... 4 Code of Conduct ........................................................................................................................4 Rules of Conduct........................................................................................................................4 Our Team ...................................................................................................................................5 Confidentiality ...........................................................................................................................5 Lost and Found ..........................................................................................................................5 No Solicitation ...........................................................................................................................5 Accepting Gifts and Favors .......................................................................................................6 Consenting Relationships (Supervisor/Employee) ....................................................................6 Parking .......................................................................................................................................6 Lockers .......................................................................................................................................6 Use of Personal Cell Phones ......................................................................................................6 Meals and Restaurant Use ..........................................................................................................6 Event Attendance .......................................................................................................................7 Employee Gambling ..................................................................................................................7

Attendance.................................................................................................................. 8 Attendance Point Chart ..............................................................................................................9 High Volume Business Days ...................................................................................................10 Inclement Weather ...................................................................................................................11

Your Appearance .....................................................................................................12 Clothing and Accessories .........................................................................................................12 Shoes and Stockings ................................................................................................................13 Prescription Eyeglasses ............................................................................................................14

Contents

September 1, 2015 i

Contents

Mission Statement .................................................................................................. 1

Our Vision ..................................................................................................................................1

Our Mission ...............................................................................................................................1

Our Core Values ........................................................................................................................1

Welcome and Introduction ...................................................................................... 2

Pokagon Gaming Authority .......................................................................................................2

Communication ..........................................................................................................................2

Equal Employment Opportunity ............................................................................. 3

At Will Employment ..................................................................................................................3

Employment of Relatives ...........................................................................................................3

Our Expectations of You......................................................................................... 4

Code of Conduct ........................................................................................................................4

Rules of Conduct........................................................................................................................4

Our Team ...................................................................................................................................5

Confidentiality ...........................................................................................................................5

Lost and Found ..........................................................................................................................5

No Solicitation ...........................................................................................................................5

Accepting Gifts and Favors .......................................................................................................6

Consenting Relationships (Supervisor/Employee) ....................................................................6

Parking .......................................................................................................................................6

Lockers .......................................................................................................................................6

Use of Personal Cell Phones and Other Technology .................................................................6

Meals and Restaurant Use ..........................................................................................................7

Event Attendance .......................................................................................................................7

Employee Gambling ..................................................................................................................7

Attendance .............................................................................................................. 9

Attendance Point Chart ............................................................................................................10

High Volume Business Days ...................................................................................................11

Inclement Weather ...................................................................................................................12

Your Appearance .................................................................................................. 13

Clothing and Accessories .........................................................................................................13

Shoes and Stockings ................................................................................................................14

Prescription Eyeglasses ............................................................................................................15

Contents

ii September 1, 2015

Cosmetics and Jewelry .............................................................................................................15

Hairstyles, Beards, Mustaches, and Sideburns ........................................................................15

Harassment ........................................................................................................... 16

Sexual Harassment ...................................................................................................................16

Reporting Harassment ..............................................................................................................16

Work Safety .......................................................................................................... 18

Injuries to Employees ..............................................................................................................18

Non-Employee Injuries ............................................................................................................18

Driving Vehicles ......................................................................................................................18

Bloodborne Pathogens .............................................................................................................18

Performance Guidelines ........................................................................................ 19

Performance Evaluations .........................................................................................................19

Disciplinary Guidelines ...........................................................................................................19

Board of Review ......................................................................................................................20

Who Can Use the Board of Review ...................................................................................20

Hours and Pay ....................................................................................................... 21

Recording of Hours ..................................................................................................................21

Overtime ..................................................................................................................................21

Rest Periods (Breaks) ...............................................................................................................21

Meal Periods ............................................................................................................................21

Meetings ...................................................................................................................................21

Holidays ...................................................................................................................................22

Pay Periods...............................................................................................................................22

Employee Benefits ................................................................................................ 23

Health and Dental Insurance ....................................................................................................23

Life Insurance ..........................................................................................................................24

Activity Sponsorships ..............................................................................................................24

Funeral Donation .....................................................................................................................24

Purchase Discounts ..................................................................................................................24

Paid Absences ....................................................................................................... 25

Paid Time Off (PTO) ...............................................................................................................25

Holidays ...................................................................................................................................25

Funeral Leave...........................................................................................................................26

Military Duty ...........................................................................................................................26

Pay While on Military Leave .............................................................................................26

Reinstatement Rights Upon Returning from Military Leave .............................................26

Contents

September 1, 2015 iii

Jury Duty ..................................................................................................................................27

Unpaid Absences .................................................................................................. 28

Medical Leave ..........................................................................................................................28

Personal Leave .........................................................................................................................28

Substance and Alcohol Abuse ............................................................................... 29

Substance Abuse ......................................................................................................................29

Alcohol Abuse .........................................................................................................................29

Drug and Alcohol Testing ........................................................................................................29

Employees Seeking or Completing Treatment ........................................................................30

Smoking ...................................................................................................................................30

Responsible Gaming Mission Statement ............................................................... 31

Terminating Employees ........................................................................................ 32

Handbook Receipt ................................................................................................ 33

Addendums and Read & Sign Documents ............................................................ 35

Contents

iv September 1, 2015

Mission Statement

September 1, 2015 1

Mission Statement

Our Vision

To provide a gaming experience unlike any other in the Midwest.

Our Mission

We will:

Delight our guests.

Develop a superior team of Employees.

Respond to community needs.

Maximize value to our owners and managers.

Our Core Values

We are committed to excellence and to operating with innovation, integrity, and ethics in

all aspects of our business.

We will maintain our values of:

Teamwork

Respect

Integrity

Fun

Through these values, technology, and training, we will:

Exceed guest expectations with superior products and service.

Attract, develop, and retain a superior team of Employees.

Establish an environment of operational excellence and marketplace positioning

for Four Winds.

Meet the profit objective of our owners and managers.

Four Winds Employee Information Handbook Welcome and Introduction

2 September 1, 2015

Welcome and Introduction

Pokagon Gaming Authority

Thank you for committing your time and talent to Four Winds.

Four Winds is owned by the Pokagon Gaming Authority (PGA), a chartered Enterprise of

the Pokagon Band of Potawatomi Indians.

Four Winds’ philosophy is to create an environment that encourages and rewards team

effort and to develop a culture that is goal-oriented, success-driven, and consistently fair

to Employees, guests, and community members.

There are some things we believe to be very important to our success in this effort:

We must remember at all times that the guest is the reason we exist.

We are in the entertainment business, and we must entertain and delight our

guests.

Our operations are a team effort, and we expect all Employees to make a major

contribution to its success. There is no they, them, or their; but instead only us,

our, and we.

It takes competent, dedicated Employees to meet the needs and wishes of our

guests.

We are committed to providing all Employees with the appropriate training and

support they need to be successful.

Communication

Four Winds uses an open-door communication policy. You should feel free to raise and

discuss constructive suggestions or concerns you may have regarding your job, working

conditions, or policies with your Supervisor without fear of retaliation. When you have

an issue you would like to discuss, you should, if at all possible, follow the chain of

command within your department.

Four Winds has also established a formal grievance process, the Board of Review, for

you to use. See the Board of Review section for more information.

Please Note: If you do not understand something, or would like more detailed

information, contact the Human Resource Department.

Equal Employment Opportunity

September 1, 2015 3

Equal Employment Opportunity

Where required by law and/or policy, Four Winds will recruit, select, train, assign,

promote, transfer, layoff, recall, terminate, and administer all wage and benefit programs

without regard to race, color, religion, national origin, age, sex, marital status, disability,

or sexual orientation.

If you have a physical or mental impairment that substantially limits one or more major

life activities and you require accommodations to do your job, please see your Human

Resource Department.

One of Four Winds’ employment goals is to attract, hire, and retain Native Americans.

Within this context, we will practice Native American preference, including but not

limited to, hiring and training.

At Will Employment

Four Winds employees are employed ―at will‖. This means that either Four Winds or the

employee may terminate the relationship at any time without prior notice and for any

reason. In no case is the hiring of an employee considered a contractual relationship

unless specified in writing.

Employment of Relatives

Relatives of current Employees are eligible for employment. Close relatives and those

with close relationships may not directly supervise each other. A close relative or

relationship is defined as a spouse, significant other, child, grandchild, stepchild, parent,

grandparent, stepparent, sibling, stepbrother, stepsister, brother-in-law, sister-in-law,

mother-in-law, father-in-law or an individual that is or was raised in or lives in the same

household. The supervisor or manager must immediately withdraw from any activity or

decision that would reward or disadvantage the close relative or relationship. Only the

Chief Operating Officer can approve exceptions.

Certain departments (e.g., Surveillance and Security) may limit where in the Casino

family members of their departmental employees are permitted to work. If you have any

questions, please see Human Resources or your Supervisor.

Four Winds Employee Information Handbook Our Expectations of You

4 September 1, 2015

Our Expectations of You

Code of Conduct

An Employee Code of Conduct has been established to protect the safety of all

Employees and guests, to maintain efficient guest service, and to protect our goodwill

and property. You should be aware that your behavior on and off the job while on Four

Winds’ property or in uniform reflects upon Four Winds’ integrity and image.

Rules of Conduct

You are expected to conduct yourself in a professional, ethical, and positive manner at all

times.

Inappropriate behavior that violates the Employee Code of Conduct may lead to

disciplinary action up to and including termination. The following list is not complete,

but will serve as a guide to what Four Winds deems inappropriate:

Excessive absenteeism, tardiness (including returning from meal or rest breaks),

or time away from the work area.

The theft of Four Winds’ property or money, or the property or money of another

Employee or guest on Four Winds’ property.

Falsifying work/attendance records for another Employee or having another

Employee falsify such records for you.

Consuming, being under the influence of, possessing, distributing, or attempting

to distribute, intoxicants or illegal drugs.

Obtaining employment on the basis of false or misleading statements.

Unauthorized possession, willful destruction, or defacement of Four Winds,

Employee, or guest property.

Insubordination or the use of abusive, threatening, or obscene language.

Violation of any health, safety, or security rules.

Gambling or promoting lotteries or other types of betting pools, except where

authorized by Four Winds.

Possession of a dangerous weapon.

Failure to comply with Four Winds’ Drug and Alcohol Policy.

Giving out, or in any way disclosing, confidential Four Winds’ (including

Employee-related) information.

Any form of harassment, acts, or threats of violence against other Employees,

guests, vendors, or visitors to the property.

Failure to follow Four Winds’ procedures on responsible alcohol service.

Job abandonment.

Any action that management deems inappropriate behavior while on work time

or on the property.


September 1, 2015 5

Our Team

All Employees at Four Winds are members of the same team. Smooth teamwork ensures

a pleasant atmosphere for our guests.

Remember to:

Treat all fellow Employees courteously and respectfully; that is, treat them how

you would like to be treated.

Never chastise, verbally abuse, or ridicule any fellow Employee.

Encourage Employees who are new or inexperienced. One way to do this is to

share your knowledge and assist whenever possible.

Pull your share of the workload. Never expect another Employee to do your

work.

Never bicker or quarrel with another Employee in any public area. If there is a

problem or misunderstanding, attempt to alleviate or correct the problem by

discussing it in a private area in a mature and professional manner. Ask

management to mediate if you feel it is necessary.

Do not talk about, degrade, or chastise fellow Employees with others. This can

create animosity between Employees that makes it difficult to work as a team.

Do not gossip or spread rumors about any Employee.

If you have a problem or dispute with an Employee who does not work in the

same department as you do, inform your Manager so appropriate action can be

taken.

Do not intimidate, flirt with, or make sexual comments about or to another

Employee. This is harassment, and is against Four Winds policy.

Confidentiality

Maintain confidentiality regarding any information, business plans, or materials that you

may be exposed to while performing your job. This information, plans, and materials are

the property of Four Winds and may not be removed or copied under any circumstances.

Employees who carelessly or deliberately disclose or provide confidential information to

those who do not have a legitimate business need to know will be subject to disciplinary

action up to and including termination.

Lost and Found

All Lost and found items must be turned in to Security. When turning in an item, you

may be asked to complete a form.

No Solicitation

Solicitation, for any purpose, is prohibited by Employees and non-Employees alike,

during working time anywhere on Four Winds property. However, Management reserves

the right to sponsor charitable solicitation activities. There will be no discrimination or

retaliation against Employees because of their willingness or unwillingness to contribute

or participate in such approved activities. Employees violating this policy will be subject

to disciplinary action up to and including termination.


6 September 1, 2015

Accepting Gifts and Favors

It is inappropriate for you to accept substantial gifts or favors from guests, vendors, or

others conducting or attempting to conduct business with us. In this case, substantial

gifts or favors refers to those valued at $200.00 or more. The cumulative total of all such

gifts received from a single individual or company in a calendar year is limited to $500.

This statement is not intended to prohibit the acceptance of normal gratuities (tips and

tokes); however, hustling, suggesting, or demanding that any type of normal gratuity is

required or expected for any service is strictly prohibited.

Consenting Relationships (Supervisor/Employee)

Consenting ―romantic‖ or sexual relationships between Management and an Employee

who share a reporting relationship (directly or indirectly) is prohibited. If a romantic or

sexual relationship between Employees with a reporting relationship develops, it shall be

the responsibility and mandatory obligation of the Management to immediately disclose

the existence of the relationship to his/her Department Head. An Employee who fails to

report the existence of such a relationship will be subject to disciplinary action up to, and

including termination.

Parking

During the time you are at work you are required to park in designated areas. Each

employee must have a parking permit and it must be displayed while the vehicle is in the

employee parking area.

The designated pick up/drop off point for employees who are driven to work is in the

employee parking lot. Employees should not be dropped off or picked up in areas or areas

designated for deliveries or guests.

The Security Department will conduct periodic inspection of all parking areas.

Lockers

Lockers are available to employees on a first come first served basis, upon request of

their department Administrative Assistant. Lockers are the property of Four Winds,

provided for the convenience of storing car keys, cell phones, and personal items that

employees may not be able to take into work areas. Each locker has a unique combination

which is reset when the locker is assigned to an employee. Under no circumstances

should employees share lockers or use padlocks. Four Winds reserves the right to inspect

lockers without prior notice or consent.

Use of Personal Cell Phones and Other Technology

Unless issued by Four Winds, employees may not use personal cell phones while on duty.

Personal cell phones may not be visible or audible. Use of cell phones is authorized

while on a break from work; however, you may not use your phone in guest areas.

The use of wearable technology or video recording-capable devices (E.g., watches,

eyeglasses) while on duty may constitute an invasion of employees’ personal privacy or

breach the confidentiality of Four Winds protected information. Therefore, using

wearable technology with audio or video recording-capability is prohibited without prior

permission from the Chief Operating Officer.


September 1, 2015 7

Meals and Restaurant Use

While on shift, assuming you are not in uniform, you may dine in or request take-out

from any of the food outlets. You may not dine in a food outlet at any time, on or off

shift, while in uniform. Also, you should not attempt to dine at a food outlet if there is a

line waiting to enter; this guideline applies whether you are on or off shift.

Event Attendance

In order to effectively service our guests and open up avenues for new clientele,

employees will only be permitted to purchase tickets and/or attend concerts or events in

Silver Creek Event Center during specially designated promotions which will be

announced in advance. Employees are not permitted to accept complimentary tickets

from guests to any concerts or events.

Employee Gambling

Prohibitions:

Management at a Director level or above and Surveillance Department personnel are

prohibited from gaming at all Four Winds properties.

Employees assigned to a satellite casino property are prohibited from gaming at any

satellite casino location. These employees may game at the main casino property in

New Buffalo.

All Slot Department Technicians, Information Technology Department Technicians,

and Planning and Analysis employees are prohibited from playing slots at Four

Winds properties.

All Table Games Employees at the levels of Supervisor and above are prohibited

from playing live table games at Four Winds properties.

All other Employees working at Four Winds may gamble at Four Winds. If you have any

question about your eligibility to gamble, see your Supervisor or the Human Resource

Department.

Employees who gamble under this policy must adhere to the following:

You must be 21 in order to gamble.

You may participate in any gaming activities only when you are off duty.

You may not join Four Winds Player’s Club or redeem coupons.

You may not wear any clothing that identifies you as an Employee of Four Winds

while gambling. This includes nametags and ID badges. However, you must be

suitably attired while at Four Winds and off duty.

You must conduct yourself in a professional and courteous manner while gambling.

Any Employee who exhibits behavior that reflects negatively upon Four Winds will

be asked to leave the Casino and may be disciplined, up to and including

termination.

You may not gamble within two hours of clocking-in or clocking-out of work.

You may not bet more than $25 on ―high stakes‖ table games.

You may not play progressive slot machines or slot machines with a payout award

greater than $5,000.


8 September 1, 2015

You may not apply for or receive Casino credit.

You may not be intoxicated while off duty and at Four Winds, and you must

comply with Four Winds’ alcohol policy.

Any Employee who violates this policy will be subject to disciplinary action up to and

including termination.

Attendance

September 1, 2015 9

Attendance

Four Winds’ attendance policy ensures that all Employees understand the importance of

being at work when scheduled and provides guidance to supervisors on how to address

those Employees who are chronically absent or late for work. Four Winds operates a

business that provides a delightful entertainment experience to our Guests. Therefore, it

is vital to have staffing levels that are appropriate to satisfy the needs of the Guest. This

can be accomplished only with all Employees being at work when they are scheduled.

Absenteeism and tardiness not only detract from our ability to provide this experience but

place undue hardship on fellow Employees and may increase operating expenses.

Employees should understand that absenteeism and tardiness are controllable. A

consistent trend or pattern of absences may be grounds for termination. A pattern is

defined as more than two identical occurrences within a three (3) month period.

An absence or tardiness is defined as not reporting to work as scheduled. In the case

of inclement weather or other unforeseeable situations, the Chief Operating Officer

reserves the right to override the policy but not on an individual basis.

An absence from work will be excused in situations for serious medical

conditions/emergencies of the employee or that of the employee’s dependent minor

child, dependent child incapable of self-care because of a mental or physical

disability, or spouse. If a note is submitted, it must be submitted on the next

scheduled day upon the employee’s return to work. Notes submitted after the

employee’s next scheduled day will not be accepted. A doctor’s note does not excuse

pattern absence or no call no show absences unless the employee is incapacitated and

not able to call his/her supervisor.

If an Employee is unable to report for work, he/she must notify the manager or

supervisor immediately. Notification must occur no less than one (1) hour before the

Employee’s scheduled starting time. Even with notification, the absence will be

counted as an attendance infraction. The Employee may be assessed an additional .5

attendance point if he/she fails to call before the start of the shift.

If an Employee does not notify their department but shows up for work within one

(1) hour after their shift starts, they will be assessed .5 point. Employees may not be

allowed to work if they show up more than one (1) hour after their shift starts.

Employees who are released from work and work less than half of their scheduled

shift will be assessed 1 point. If they work more than half their scheduled shift, they

will be assessed ½ point. Scheduled time off must be approved in advance except for

military leave of absence. Time off is covered under a separate policy (Paid Time

Off, Leave of Absence, Holidays, Funeral Leave, and Jury Duty).

Employees who have a paid time off (PTO) balance will have PTO automatically

deducted if they are absent unless stated otherwise in writing using the appropriate

form. In the case of continual or intermittent medical leave, the Employee must take

the remaining balance of PTO in accordance with policy.

Four Winds Employee Information Handbook Attendance

10 September 1, 2015

The absence/tardiness standard is ten (10) points in a rolling 12- month period,

beginning with the first absence/tardiness. All absences/tardiness should be recorded

on the Employees attendance calendar located in the Employee’s home department.

Employees may ask their supervisor/manager to review their attendance calendar.

If an Employee is not absent or tardy for 90 days, the oldest occurrence not to exceed

two (2) points on his/her attendance calendar will roll off. The absence/tardiness

standard is ten (10) points in a rolling 12-month period. At the end of the 12 months,

the oldest occurrence will roll-off.

Attendance Point Chart

Absences

Call off prior to start of shift 1 point

Call off prior to start of shift on a High Volume Business Day 1.5 points

Call off prior to start of shift when Request for Time Off was denied 2 points

Call off more than (1) one hour after start of shift , or no notification of

absence is considered a No Call/No Show (NC/NS)

3 points

Consecutive Day Absences

Consecutive day call off prior to start of shift .5 point

Consecutive day call off prior to start of shift on a high volume business day 1 point

Consecutive day call off more than (1) one hour after start of shift , or no

notification of absence is considered a no call no show (NC/NS)

3 points

Tardies and Leaving Before End of Shift

Tardy is up to (1)one hour after start of shift .5 point

Showing up for work, but working less than half scheduled work time 1 point

Showing up for work, but working more than half scheduled work time but

unable to complete the shift.

.5 point

Below are the steps that will be used when taking disciplinary action as it relates to absenteeism and tardiness for non exempt employees.

Attendance Points Action To Be Taken

5 points Record of Discussion (Verbal Form)

7 points Written Warning

8 points Final Warning Notice

9 points Suspension

1st Pattern Absence Suspension

Ten (10) attendance points is grounds for termination. Each step of the disciplinary process does not have to be followed.

1. The first time an Employee has a No-Call/No-Show, the Employee will receive a

written Final Warning. A second No-Call/No-Show occurrence may include

disciplinary action, up to and including termination. If an Employee has three (3)

Attendance

September 1, 2015 11

consecutive days as a No-Call/No-Show, the Employee will be considered to have

resigned his/her employment and will result in termination.

2. When an Employee has been denied a request for time off and calls out on the day(s)

which were denied, the Employee will be charged two (2) points unless credible

evidence is provided verifying the Employee was unable to report to work because of

circumstances beyond his/her control. The Employee will then receive points that

apply to the day missed.

3. Exceptions will be made for emergency situations that prevent an Employee from

calling in or coming to work as scheduled, the Director or Vice President of the

Employee’s department will recommend an appropriate course of action to the

General Manager for approval. No termination will occur without the Chief

Operating Officer’s approval.

4. The Director or Vice President of the department must approve all recommendations

of terminations for absenteeism/tardiness, in consultation with the senior member of

Human Resources. On-the-spot terminations cannot be made by a supervisor.

Human Resources is available to serve in an advisory capacity when termination is

being considered. The steps to take when considering termination for an

absenteeism/tardiness offense are:

Send Employee’s file with all related documented offenses to the Director or

Vice President of the department.

The department manager reviews all documentation and meets with the

senior member of Human Resources to ensure that all documentation is in

order for disciplinary action and/or termination. The department Director or

Vice President with the counsel of HR determines the appropriate

disciplinary action.

The appropriate member (Manager/Supervisor) of the department meets with

the Employee to discuss the recommended disciplinary action.

The Employee will not be eligible for a Board of Review.

High Volume Business Days

The following major nationally recognized holidays are considered high volume:

New Year’s Day Labor Day Memorial Day Thanksgiving Day Independence Day Christmas Day

In addition to these nationally recognized holidays the following will also be considered

high volume days:

New Year’s Eve

New Year’s Weekend

Martin Luther King (MLK) Day

President’s Day

Columbus Day

Veteran’s Day

Four Winds Employee Information Handbook Attendance


Day after Thanksgiving Day

Thanksgiving Day weekend

Sundays before existing Monday holidays (e.g., Sunday before Labor Day,

etc.)

Promotional days as identified by management

Other days as designated by department(s)

Management reserves the right to make adjustments to this list.

Inclement Weather

Four Winds is a 24-hour, 7-day a week entertainment facility, which does not close. It is

anticipated that you arrive for your shift as scheduled unless given other instructions by

your supervisor or manager. Inclement weather notification and instruction will be

announced through the property hotline: 866-4WINDS4 or 866-494-6374.

Management should arrive as scheduled to carry on the necessary function of the

property and be available to employees and guests. Should you not be able to report to

work, you must call your supervisor per standard process and procedures. Points will be

assessed. However, should an inclement weather day be called, those points will not be

counted toward your cumulative point balance.

Your Appearance


Your Appearance

It is important to the overall image of Four Winds that Employees maintain a pleasant

and professional appearance at all times. If you are in violation of this policy, you may

be subject to disciplinary action up to and including termination and/or be sent home

without pay to alter your appearance.

Please note: The following appearance and uniform guidelines are for general use.

Standards may vary somewhat based on department or venue. Please see your manager

for standards specific to your position.

You must always be well groomed and suitably attired while on duty. Some general

guidelines include:

Never forget that you represent Four Winds in the eyes of the guests.

Take pride in presenting a professional appearance.

Practice good hygiene and grooming at all times.

Always use deodorant and antiperspirant.

Use light cologne only. No heavy fragrances are permitted.

Be conservative in your use of cosmetics, perfume, jewelry, dress and hairstyle.

Avoid slouching or placing hands in pockets while wearing a uniform or while

on duty.

Keep your fingernails neat and clean at all times.

Do not smoke, chew gum or ingest food or beverages while on duty or in guest

areas.

Facial jewelry, piercings, and modifications, other than pierced earrings in ears,

are not allowed.

Tattoos that are obscene or advocate sexual, racial, ethnic, or religious

discrimination, as well as tattoos that may bring discredit upon the Tribe or Four

Winds, are prohibited. You may not display excessive tattoos that would detract

from a professional image. Excessive tattoos are those which cover more than

25% of the exposed body part.

Clothing and Accessories

Uniform requirements must be adhered to by all Employees. Depending on your job,

Four Winds may or may not furnish uniforms. If you have questions about the uniform

policies, ask your Supervisor.

Uniforms are required at all times for designated Employees. You are required to

conform to your department’s dress code. Ask your Supervisor if you have questions

about what is appropriate.

Make sure your clothing is always clean and well pressed. In some cases, Four

Winds may clean your uniform for you. In all other cases, it is up to you to keep

your uniform and other clothing clean and in good condition.

Wear a uniform if required. Make sure your uniform is complete and properly

worn.

Four Winds Employee Information Handbook Your Appearance


Unless otherwise instructed by Management, be in uniform before you clock in

for work.

Do not wear your uniform when you are off duty, except when in transit to or

from work.

Wear your nametag at all times while you are representing Four Winds.

Do not wear faded clothing. If you are required to wear black, make sure it is

true black.

Do not wear casual clothing. Business casual is acceptable if you are not

required to wear a uniform.

Button your shirtsleeves at the wrist: do not roll up sleeves.

Do not wear clothing that is excessively tight, revealing, or extremely oversized.

Skirts must be worn no shorter than three inches above the knee and no longer

than mid-calf.

Appropriate undergarments must be worn.

Wear pins or buttons provided by Four Winds only. No other pins or buttons are

permitted.

Do not wear the following items:

Turtlenecks under uniform shirts – unless approved by Management and

provided by Wardrobe.

Sweaters over uniform tops – unless approved by Management and

provided by Wardrobe.

Four Winds logo clothing from the Gift Shop – unless the clothing is worn

as part of business casual-wear.

White socks.

White athletic shoes.

Denim clothing (unless part of your uniform).

Cargo pants, capri pants, shorts, leggings, or spandex clothing.

Tank tops, halter tops, tube tops, or spaghetti strap tops.

Leather pants or skirts.

Outdated marketing event pins.

Pants with rivets or stitched pockets.

Hats that are not part of your uniform.

Sundresses, low-cut, midriff or transparent tops or dresses.

Shoes and Stockings

Keep your shoes shined and in good condition.

Wear black non-skid shoes that are practical and safe for your type of work.

Casual and recreational footwear (tennis shoes, sandals, platform shoes) are not

permitted

Open-toed shoes are permitted unless prohibited by the uniform or department.

Backless shoes are not allowed; however sling back shoes are acceptable.

Male Employees are required to wear socks that match their shoes.

Your Appearance


When required as part of a uniform, female Employees must wear hosiery with

skirts or black dress socks with trousers. Patterned hosiery is not permitted.

Wear dark socks and hosiery only unless your uniform requires otherwise.

Prescription Eyeglasses

Wear glasses with a light tint or no tint.

Do not wear dark glasses unless it is medically required and prescribed by a

doctor. Dark glasses prevent eye contact and may interfere with your ability to

serve our guests.

Cosmetics and Jewelry

Use conservative nail polish only: colors such as blue, black, purple, green, or

glitter colors are not permitted. Other guidelines may apply if your job involves

preparing, handling, or serving food.

Fingernails should not be of excessive length.

Use cosmetics that are natural looking and appropriate. No excessive or wild

eye shadows, lipsticks, or blush are permitted.

Keep jewelry simple and unobtrusive. A maximum of seven pieces of jewelry is

allowed. Multiple necklaces, bracelets or rings are not permitted.

(Engagement/wedding ring set counts as one ring.)

Do not wear earrings that are larger than a quarter. Depending upon your job,

you may not be able to wear earrings or that dangle. One earring only per ear is

allowed.

Hairstyles, Beards, Mustaches, and Sideburns

Hairstyles must be appropriate for business, cultural, and religious standards. Hair must

be worn so that it does not block side vision, cover the nametag, or present a security

problem. Hair restraints may be required at Management’s discretion.

Do not use extreme hair colors (e.g., purple, green, bright yellow, red, pink).

Afro or natural hairstyles are permitted if neatly shaped to meet hairstyle

guidelines.

Do not weave beads into your hair.

Wild hairstyles are not permitted.

Keep long hair neat and under control.

If you serve food, keep your hair off your shoulders and serving trays.

You may wear hair accessories if they are in style with your uniform.

Generally, mustaches, beards, and sideburns, are allowed as long as they are

neatly trimmed and conservative. Mustaches must not extend below the upper

lip or beyond the corners of the mouth. Management reserves the right to restrict

the wearing of mustaches, sideburns and beards in certain departments.

Please see department and venue specific guidelines for more information.

Four Winds Employee Information Handbook Harassment


Harassment

It is the policy of Four Winds to provide a work environment that is free from

harassment, based on race, color, religion, national origin, age, sex, marital status,

disability, or sexual orientation. All harassment is prohibited, regardless of where it

occurs, if the harassment affects the terms and conditions of employment.

Sexual Harassment

Sexual harassment is one form of prohibited harassment. Some examples of sexual

harassment are:

Making unwelcome sexual advances, requests for sexual favors, or other verbal

or physical conduct of a sexual nature, a condition of the Employee’s continued

employment.

Making employment decisions based on submission to, or rejection of, such

conduct.

Stating or implying that a particular Employee’s advances and employment result

from the granting of sexual favors or the establishment of or continuation of a

sexual relationship.

Stating or implying that a particular Employee’s deficiencies and performance

are attributable, in whole or in part, to the sex of that person.

Commenting on a particular characteristic associated with a particular sex.

Creating an intimidating, hostile, or offensive work environment by such

conduct.

Reporting Harassment

Employees who believe they are being harassed should immediately:

Tell the harasser that the action is unwelcomed, and they must stop.

(Employees who feel uncomfortable approaching the harasser may report the

incident as listed below.)

Immediately report the specific incident of harassment to the Manager, Director,

or Vice President of Human Resources. If a Human Resource representative in

not available, immediately report the incident to your supervisor.

Report any further incident(s) of harassment to a Human Resource

representative, or your immediate supervisor.

The Human Resource department, with the assistance of the Security Department will

investigate all reports of harassment as quickly and confidentially as possible.

Four Winds strictly prohibits any retaliation against an employee who:

Reports suspected harassment.

Furnishes information regarding a report of harassment.

Participates in any manner in an investigation, hearing or any activity related to

the report.

Harassment


We recognize that false allegations of harassment and/or discrimination can have serious

effects. Such actions may also result in disciplinary action up to and including

termination.

Four Winds Employee Information Handbook Work Safety


Work Safety

You are expected to observe all rules of safety at all times. If you notice any unsafe

conditions, report them to management immediately.

Injuries to Employees

Immediately report an injury or illness to your Supervisor if you:

Are injured while on work-related business.

Witness another Employee’s injury.

Have a work-related illness.

If your Supervisor is not available, you should report the injury or illness to the Security

Department. You must report the injury or illness to the Workers’ Compensation

representative in Human Resources, assist in the completing of all necessary forms, and

cooperate fully with any investigation.

Non-Employee Injuries

Immediately report to your Supervisor if a non-Employee is in an accident on Four

Winds’ property, and you:

Are involved in the accident.

Witnessed the accident.

If your Supervisor is not available, you should report the accident to the Security

Department. You must also assist in the completing of all necessary forms and cooperate

fully with any investigation. Accident also refers to sudden illnesses.

Driving Vehicles

If you drive or ride in any vehicle on work-related business, you must follow traffic laws,

take all safety precautions, wear your seatbelt, and report all accidents and violations to

your Supervisor immediately.

If you drive a Four Winds-owned or leased vehicle, or you work as a Valet, Four Winds

will periodically review your driving record. You may also be subject to Department of

Transportation drug and alcohol testing requirements. Employees who do not maintain a

satisfactory driving record may be disciplined up to and including termination.

Bloodborne Pathogens

Depending on your job classifications, you may be offered the opportunity to have a

Hepatitis B vaccination, which is provided by Four Winds. For more information,

contact the Human Resource Department.

Performance Guidelines


Performance Guidelines

Performance Evaluations

While you will receive regular, informal feedback on your performance, you will also

receive formal performance evaluations. Pay adjustments may or may not accompany

these formal evaluations depending upon your performance and business conditions.

Performance Review Schedule:

STATUS CHANGE WHEN TO CONDUCT A PERFORMANCE

REVIEW (NO SALARY REVIEW )

WHEN TO CONDUCT A PERFORMANCE

REVIEW (SALARY REVIEW)

New Hire 90 days One year from the date in the new position

Promotion 90 days One year from the date in the new position

Demotion 90 days Retain annual review date

Transfer (with a salary increase)

90 days One year from the date in the new position

Transfer (without a salary

increase)

90 days Retain annual review date

Disciplinary Guidelines

It is our belief that all Employees wish to support the objectives of the organization.

Through Employee training and performance objectives, you will be advised of Four

Winds’ mission, the requirements of your job, and any other criteria necessary for your

success. To the extent possible, we will attempt to use progressive discipline to assist

Employees in correcting performance or behavior issues. However, Four Winds reserves

the right, at any time, to discipline or terminate an Employee at-will without prior

warning, discussion, or counseling.

Our policy provides the following measures, depending upon circumstances.

Verbal Counseling: A verbal discussion highlighting the problem(s) needing

correction. The Supervisor may include a written note in the Employee’s

personnel file containing information discussed.

Written Counseling: A Counseling Notice is prepared and discussed with the

Employee. Space is provided on the notice for the Employee to add comments

regarding counseling. The original becomes part of the Employee’s personnel

file.

Suspension (Without pay): Suspension without pay may occur when it is felt

such action is warranted. Suspensions are not to be used when there is a problem

with the Employee’s attendance, tardiness, or in no-call/no-show situations.

Discharge: Termination of employment may be immediate, depending upon the

circumstances or conduct. Employees who resign, are discharged, fail to return

to work as scheduled, or are laid-off will be regarded as having terminated their

Four Winds Employee Information Handbook Performance Guidelines


employment. In such cases, all Four Winds’ property must be returned. In

addition, any amounts due to Four Winds will be deducted from the final

compensation in accordance with applicable laws.

Important Note: Although Four Winds may use progressive discipline, nothing shall

limit Management’s absolute right to terminate and/or lay off any Employee at any time,

with or without cause. Employees also retain the right to terminate employment at any

time for any reason.

Board of Review

Four Winds has established a formal grievance process, the Board of Review, for you to

use. It is our policy to provide employees with a procedure for bringing work related

issues not related to attendance to management’s attention in an effort to promptly and

permanently resolve them in a fair and equitable manner. Issues which are presented in

this type of system usually concern a term or condition of employment, treatment by

supervision, management, or another employee. It is also used by individuals who

disagree with some form of disciplinary action up to and including termination.

Who Can Use the Board of Review The Board of Review process is available to all Employees except: Employees at the

Manager level and above or Employees terminated for actions stemming from

violence and/or threats of violence, harassment, time and attendance , violation of

Pokagon Gaming Authority rules and regulations, violation of local ,state and/or

federal laws. For an Employee to be eligible to use the process, these steps must be

followed in order, and he or she must have completed 90 days of continuous

employment:

1. Progressed through the entire chain of command in their home department for

attempted resolution.

2. Brought the situation to the attention of the Human Resource department for

attempted resolution,

3. Completed a Board of Review Hearing Request Form within the allotted

timeframe. (The Board of Review Hearing Request Form is available in the

Human Resource Department.)

Please Note: If you do not understand something, or would like more detailed

information, contact the Human Resource Department.

Hours and Pay


Hours and Pay

Four Winds is open 24 hours a day, seven days a week. Your Supervisor will schedule

your hours of work in the interest of delighting our guests.

Recording of Hours

Hourly Employees are required to record all hours worked. Hours are to be recorded

electronically, registering the starting time and ending time of every shift worked.

Falsifying or failing to record hours will result in disciplinary action up to and including

termination.

Overtime

At times, it may be necessary for your schedule to include overtime hours. Overtime is

defined as any time worked over 40 hours in any one work week. Please note: the 40

hours do not include holiday hours not worked or PTO hours.

Management must approve all overtime. Hourly Employees are not permitted to work

any period of time other than their normally scheduled hours unless directed to do so by

their Supervisor. If hourly Employees work overtime, their rate of pay will be one and

one-half times their regular rate of pay.

Salaried Employees are exempt from overtime pay.

Rest Periods (Breaks)

You are allowed one 15-minute rest period (break) for each consecutive four-hour period

you work. You will be compensated for this time. Your Supervisor will schedule all

breaks.

Note: Breaks for Dealers may occur more frequently (if the schedule allows).

Meal Periods

Paid meal periods, which are usually half an hour in length, will be provided for

Employees who are scheduled to work five hours or more in a shift. Employees taking

paid meal periods are required to remain on Four Winds’ property. Salaried Employees

may eat off property only after receiving Supervisor approval.

Meetings

The following pay rules apply to meetings:

Mandatory: Hourly Employees must be compensated for all time spent at

mandatory meetings. Hourly Employees not scheduled to work will be

compensated for a minimum of four hours.

Voluntary: Meetings that require only voluntary attendance may be scheduled at

any time. Hourly Employees will not be paid for this time, unless the meeting

falls during the Employee’s regularly scheduled hours.

Four Winds Employee Information Handbook Hours and Pay


Holidays

Full-time hourly (Non-Exempt) Employees are eligible for the following holidays:

New Year’s Day

Memorial Day

Independence Day (July 4)

Labor Day

Thanksgiving Day

Christmas Day

Full-time hourly Employees who do not work on the listed holidays will receive holiday

pay equal to their regular hourly rates or minimum wage whichever is higher.

Full-time and part-time Employees who work on the holidays listed above will be paid at

their regular hourly rate for all hours worked, in addition to eight hours holiday pay.

To receive any holiday pay, Employees must work their scheduled day before and after

the holiday.

Salaried (Exempt) Employees: In lieu of holidays, salaried Employees earn PTO at a

higher rate. The additional PTO may be used for time off on a holiday, schedule

permitting.

Pay Periods

Pay periods are two weeks in length and run from 12:00 a.m. on Monday through 11:59

p.m. on Sunday. You will be paid on alternate Mondays for all hours worked.

Employee Benefits


Employee Benefits

The following pages describe the variety of benefits offered by Four Winds. Your

eligibility for these benefits may depend upon the number of hours you work over a

certain time period. To find out more about your benefits eligibility status, please contact

your Human Resource Department.

When eligible, all your premiums for health, and dental benefits may be deducted on a

pre-tax basis. This means that if you sign up for health and dental insurance, your

payments will be taken out of your paycheck before income taxes are calculated.

You may continue your health and dental insurance coverage for a period of time at your

own expense after your employment is terminated. To do so, you must notify Human

Resources of your intent to continue your coverage and make arrangements to pay for the

coverage. When your employment is terminated, the Human Resource Department will

provide you with the information necessary to continue your coverage at your own

expense.

The entire benefit program is routinely reviewed by Management to ensure that it

continues to serve the needs of the Employees.

Health and Dental Insurance

When eligible for medical and/or dental benefits, you may elect to:

Cover yourself only

Cover yourself and your family

Decline coverage altogether

You may change these elections during Four Winds’ annual open enrollment period.

These elections may also be changed under certain circumstances known as changes in

family status. If you have a change in family status, you must send written notice to the

Human Resource Department within 31 days to change your benefit elections.

Some examples of changes in family status include:

The birth/adoption of a child

Marriage

Death

Divorce

A network of doctors, clinics, hospitals, and pharmacies has been selected to provide you

with healthcare services. The use of providers within the network will ensure that you

receive the highest level of benefits available under the health and dental insurance plans.

Please refer to your Summary Plan Description (SPD) for more details regarding our

health and dental insurance benefits.

Four Winds Employee Information Handbook Employee Benefits


Life Insurance

Four Winds provides this life insurance benefit at no cost to you. Accidental death and

dismemberment (AD&D) insurance benefits are also provided under this benefit plan.

Please refer to your Summary Plan Description (SPD) for more details regarding your life

and AD&D insurance benefits, or contact Four Winds’ Human Resource Department.

Activity Sponsorships

Four Winds recognizes that a well-balanced lifestyle results in healthier, more productive

Employees; therefore, Four Winds may provide limited financial support for Employees’

organized activities. For more information, please see your Human Resource

Department.

Funeral Donation

In the event of the death of an Employee, Four Winds will make a $200 donation to the

Employee’s immediate family (spouse, parent, or adult child). At the request of an

immediate family member, the check may be made payable to a specified memorial or

charity of their choice.

Purchase Discounts

You are eligible to receive a 20% discount on all logo merchandise for sale in Four

Winds’ Gift Shop (excluding items marked as special sale merchandise, cigarettes, food,

books, magazines or health and beauty aids, and Native American original artwork). You

must show your ID badge to receive the discount at the time of your purchase. You may

not purchase items during your shift, for resale, or at a time that may inconvenience a

guest. Any Employee abusing this privilege will be subject to disciplinary action up to

and including termination.

You may be eligible for discounts at other retail shops in the New Buffalo Casino. Those

discounts will be communicated to you if, and when, they become available.

Paid Absences


Paid Absences

The following types of absences may be compensated with pay.

Paid Time Off (PTO)

Eligible Employees will earn Paid Time Off (PTO) each month. PTO is to be used for

paid absences from work including vacations, sick days, unpaid holidays, and to attend to

personal business that can’t be handled during non-working hours. Whenever possible,

you should try to schedule any absence with your Supervisor at least two weeks in

advance.

For each absence from work, PTO will be deducted from your PTO balance. Any

absences will be unpaid if you do not have a PTO balance.

On your anniversary date, you may carry over up to 80 hours of PTO not used during the

year in which it is earned. Other than at termination, there will be no cash payouts for

unused PTO.

If your employment terminates with Four Winds, any PTO balance you may have

remaining will be paid to you, less any monies owed to the Casino.

PTO may be used in conjunction with unpaid leaves. PTO is not to be used for Jury Duty

leave or the first ten days of your Military Leave.

Employees will earn PTO according to the following schedule:

Months of Service

Hours per Pay Period

Days per Year

Part-Time Employees

1 - 12 0.92 3

13 – 24 1.54 5

25+ 2.46 8

Hourly Employees

1-12 1.54 5

13-24 3.08 10

25-60 4.62 15

61+ 6.15 20

Salaried Employees

1-12 4.62 15

13-60 6.15 20

61+ 7.69 25

Holidays

Please refer to the previous Hours and Pay section.

Four Winds Employee Information Handbook Paid Absences


Funeral Leave

Eligible Employees may be given up to three paid days off, depending upon travel

distance, to attend the funeral of an immediate family member. PTO may be requested to

extend this leave if necessary. An immediate family member is defined as a spouse,

significant other, child, grandchild, stepchild, parent, grandparent, stepparent, sibling,

stepbrother, stepsister, brother-in-law, sister-in-law, mother-in-law, and father-in-law. In

order to be paid for time off, proof of death and relationship to employee are required.

Documents that may provide required information include: death certificate, obituary

(newspaper/website), documentation from funeral home, letter from attending physician

or clergyman, or printed funeral program.

Military Duty

Four Winds will grant you a Military Leave if you are a draftee, volunteer, Reservist or a

member of the National Guard or Air National Guard and you have been called by the

Armed Forces, National Guard, other reserve unit, or other person/unit designated by the

President of the United States to serve as follows:

Active duty

Active duty for training

Initial active duty for training

Inactive duty training

Full-time National Guard Duty

An examination to determine your fitness to perform such duty

To request a Military Leave, notify the Human Resource Department and your

Supervisor within a reasonable time before your leave is to begin. Failure to return to

work in accordance with the reinstatement rights section below will result in the

termination of your employment.

Pay While on Military Leave

While you are on Military Leave, Four Winds will pay you the difference between your

military pay and your regular hourly wage/salary for up to 10 days per year. To make a

claim for pay while on Military Leave, you should submit proof of your military pay to

the Human Resource Department upon your return form leave.

You may choose to apply your accumulated Personal Time Off (PTO) towards your

Military Leave. You may be eligible to continue your benefits while on leave. For more

information, please speak with the Human Resource Department prior to your leave, if

possible.

Reinstatement Rights Upon Returning from Military Leave

Upon return of your Military Leave, Four Winds shall reinstate eligible persons to the

same or similar position. You must notify the Human Resource Department of your

desire to be reinstated. Your reinstatement request must be forwarded to Human

Resources anywhere between eight hours and 90 days after you return home, depending

upon the length of your leave. Please speak with the Human Resource Department prior

to your leave, if possible.

Paid Absences


Jury Duty

If you are asked to perform your civic duty to sit on a jury, you must immediately notify

your Supervisor and forward a copy of the Jury Summons to Human Resources. Upon

completion of the jury duty, you will need to provide to your Supervisor official evidence

of having served and the dollar amount paid by the court.

You will be paid for the difference between the amount paid by the court and your

regular full-time pay (holiday and overtime pay excluded). Jury duty is not considered

Paid Time Off (PTO).

Four Winds Employee Information Handbook Unpaid Absences


Unpaid Absences

The following types of absences are not compensated with pay.

Medical Leave

Eligible Employees may take up to 12 weeks of unpaid, job-protected leave. You are

eligible for medical leave if you have worked for Four Winds for at least one year, and

have worked at least 1,250 hours within the 12 months immediately prior to the leave

date.

You may take medical leave only for the following reasons:

To care for your child after birth or adoption or when receiving a child into foster

care.

To care for your spouse, child, or parent who has a serious health condition.

A serious illness or injury that prohibits you from performing your job.

A family member’s qualifying exigency leave for National Guard or Reserves.

To care for a family member injured in the line of duty.

The length of medical leave will depend upon the medical necessity of the leave.

However, the maximum time for a medical leave is 12 weeks. Intermittent leave may be

taken only when medically necessary, as evidence by a medical provider’s certification.

Four Winds will return you to the same or similar position in pay, benefits, and schedule

when your medical leave is concluded. Using medical leave will not affect your seniority.

If you have elected insurance coverage through Four Winds, the insurance will remain in

effect for the duration of the leave, provided that you make arrangements to pay your

portion of the premium. Failure to pay the required premium will result in the

termination of your coverage and COBRA continuation will be offered.

Paid Time Off (PTO) may be used in conjunction with the medical leave. However, PTO

cannot be used to extend the medical leave longer than 12 weeks. Please contact your

Human Resource Department for details on how to request medical leave and other

procedural requirements.

Personal Leave

Individuals who have been employed for at least 90 days, with satisfactory performance

ratings, may be given up to 30 days of unpaid personal leave, subject to Management’s

discretion.

You should submit any requests for personal leave in writing to your Supervisor and

forward a copy to the Human Resource Department. Your requests should state:

The reason for the leave.

The length of leave time requested.

Paid Time Off (PTO) will not accrue during your personal leave. You must use any PTO

you have during your personal leave.

Upon request, an extension of up to 30 additional days may be granted with approval

from your Senior Vice President and the Chief Operating Officer.

Substance and Alcohol Abuse


Substance and Alcohol Abuse

You have a responsibility to seek treatment for alcohol or drug abuse before a violation

of Four Winds’ policy has occurred. You may also report suspected violations of this

policy. We will treat your report confidentially. Retaliation against Employees making

such reports is prohibited. Employees violating this policy will be subject to disciplinary

action up to and including termination.

Substance Abuse

You are strictly prohibited from using, possessing, distributing, manufacturing, selling, or

being under the influence of drugs or any other controlled substance while working for

the Four Winds or on Four Winds’ property.

Under the influence of drugs means having the presence of illegal drugs within your

body in an amount in excess of levels established by federal guidelines.

Prescription drugs are to be used only by the Employee for whom the drug is prescribed

by a licensed medical practitioner. Any use of prescription drugs should be consistent

with the manner and quantity prescribed.

Alcohol Abuse

You are strictly prohibited from using, possessing, selling, or being under the influence of

alcohol while on duty. To comply with this policy, it is recommended that you refrain

from drinking alcohol at least 8 hours prior to your shift’s start time.

Under the Influence of Alcohol means having the presence of alcohol within your body

in an amount equal or greater than .02 (2/100th) of 1%.

If you are on property while off duty, you are prohibited from being intoxicated, and you

must comply with Four Winds’ alcohol policy.

Intoxicated means having the presence of alcohol within your body in an amount equal to

or greater than those set by your local laws prohibiting drunk driving.

Drug and Alcohol Testing

The following types of drug and alcohol testing may be used:

Post-accident testing

Random testing for safety-sensitive positions as well as Department of

Transportation (DOT) required testing

Reasonable suspicion testing—based upon evidence of drug or alcohol use,

whether that evidence includes credible reports of such use, behavior consistent

with such use, or other evidence

Post-treatment testing

Pre-employment testing

Employees involved in a work-related accident may be asked to submit to drug and

alcohol testing. The results of such tests may have an impact on any claim an Employee

makes for workers’ compensation benefits.

Four Winds Employee Information Handbook Substance and Alcohol Abuse


Selections for random testing are based upon job classification and DOT requirements.

You may choose to decline a drug or alcohol test; however, your declination will result in

termination of employment.

Positive initial drug and alcohol tests will result in a second confirmatory test of the same

sample at your expense. Employees whose confirmatory test is positive will be

terminated.

Results of all drug and alcohol tests shall be treated confidentially.

Employees Seeking or Completing Treatment

Prior to a violation of Four Winds’ policies, we will accommodate requests from

Employees seeking or completing treatment for drug or alcohol abuse. Employees who

enter or have completed treatment programs are subject to additional drug and alcohol

tests beyond those identified above.

Smoking

You are allowed to smoke in designated Employee areas. Smoking is not permitted on

the Casino floor or office areas. Employees who smoke outside of the designated areas

will be subject to disciplinary action up to and including termination.

Responsible Gaming Mission Statement


Responsible Gaming Mission Statement

We recognize that certain individuals may not be able to responsibly enjoy the

entertainment product we offer. We believe that it is our responsibility to be sensitive to

our Employees, guests, and host communities by proactively addressing problem

gambling.

We will:

Educate our Employees and provide them with resources to help themselves and

others.

Provide information and assistance to our guests.

Fund research and contribute to agencies that assess the prevalence and address

the treatment of gambling disorders.

Participate in industry programs and initiatives at the national and community

level to increase awareness and ensure that accurate information is placed in the

public domain.

Prevent underage gambling of all kinds.

Four Winds Employee Information Handbook Terminating Employees


Terminating Employees

An Employee who resigns, is discharged, fails to return from a leave of absence as

scheduled, or is laid off will be regarded as terminating their employment with Four

Winds.

Employees may be eligible for continuation and conversion of group health insurance

coverage, at their own cost, following termination.

All Four Winds’ property (uniforms, training materials, keys, badges, etc.) must be

returned before any final compensation will be issued. In addition, any amounts due Four

Winds as a result of loans, advances or other obligations not repaid prior to termination

will be deducted from any final compensation.

Thank you for choosing to join

the Four Winds team of Employees.

We look forward to working with you.

If you have any questions

about anything in this Handbook,

please contact

the Human Resource Department.

Handbook Receipt


Handbook Receipt

Acknowledgement and receipt of Employee Handbook:

This is to acknowledge that I have received a copy of the Employee Information

Handbook and all current addendums and Read & Sign documents, including:

Managing Guest Incidents & Illnesses

Computer Guidelines

ACES

ACES Scores

Employee Records for Managers

Service Recovery Procedure - TITO Theft or Loss

Entrance and Exit Policy

Responsible Gaming Procedure Change

CARE Refresher

Social Media

Title 31 Basics

Hazardous Communication

Password Policy

Minors/Under 21 Policy

This Handbook is an overview of Four Winds’ policies and guidelines for my conduct. I

am responsible for reading and following this Handbook and addendums for future

reference. If I do not understand something, or would like more detailed information, I

will contact the Human Resource Department.

The Employee Information Handbook is located and accessible on Four Winds Intranet

under Employee Tools. You may also request a current copy of the Handbook from

Human Resources or the Training Department.

I am aware that Four Winds reserves the full right and discretion to amend or terminate

benefits or policies and any other provisions of this Handbook. I understand that it is my

responsibility to read and comply with any and all supplemental information in addition

to this handbook.

Date ________________________

Employee Name (please print): _____________________________________________

Signature_____________________________________________________________

Four Winds Employee Information Handbook Handbook Receipt


Addendums and Read & Sign Documents


Addendums and Read & Sign Documents

Four Winds Employee Information Handbook Addendums and Read & Sign Documents


September 1, 2015

A Read & Sign Flier from the Training Department

Managing Guest Incidents & Illnesses

Please contact Security for all guest incidents and illnesses, whether the guest would

like you to or not. Examples include dizziness, passing out, tripping, slipping, or falling.

Security provides medical attention, investigates, and makes a formal report for all

incidents. Please keep the guest comfortable until Security arrives.

Do:

Call Security even if the guest does not request it, or even if they ask you not

to call.

Make the guest comfortable. Attend to their needs until Security arrives. Ask,

for example, “How can I make you comfortable? Can I get you some water?”

Notify the guest: “Security is on the way” or “Medical attention is on the way”.

If the guest asks questions about the situation, tell them, “Security or a

Manager will be able to answer that when they arrive.”

Get a Supervisor to assist you, especially when you are unsure how to handle a

guest.

Observe conditions so that you can relay them for the incident report.

When Security arrives, transition the handling of the guest to them by telling

the guest, “Security is here to help you now”. Then let Security take over.

If the incident or illness involves bodily fluids, call EVS to handle it. Any bodily

fluid has the potential to be dangerous to you. EVS has the proper equipment

and is trained to keep it SAFE.

Do NOT:

Do NOT give your own opinion to the guest of what caused the incident or how

the incident should be handled.

Do NOT discuss prior incidents with the guest.

Do NOT say that we will “take care of it”, or offer any other alleviations.

Instead, please ensure that the guest is comfortable.

Do NOT comp the guest, even if it seems like the right thing to do. Any comps

will come from the Manager in charge after Guest Services and Risk

Management staff have properly investigated the incident.

Do NOT discuss Surveillance cameras with the guest.

Do NOT conduct your own investigation; Security will perform a complete

investigation.

Do NOT clean up bodily fluids. Keep yourself safe. EVS is trained to do this.

September 1, 2015


Do NOT discuss the incident with Security in front of the guest(s). And,

Security should not question you in front of the guest. They may question you

outside the guest’s earshot to help complete the report.

Do NOT tamper with and definitely do not discard any evidence. Security will

handle the evidence following their procedures of investigation.

Guests are advised to contact the Risk Management Department. Please do NOT tell the

guest that we will contact them.

Help us keep our guests safe. Always check your work area for any potential risks, and

take action to correct those risks to help us prevent incidents: for example, chairs that

are pushed out into the aisles, objects on the floor that someone could trip over, a wet

floor or spill where there is no signage.

We can all work together to ensure that our guests and employees are kept as safe as

possible and guest incidents and illnesses are managed properly.

Thank you.

September 1, 2015


Computer Usage Guidelines

Four Winds computers are intended for professional and appropriate use. Please note the following

prohibited activities:

Please do not send, receive, or display obscene or pornographic text or graphics.

Please do not load or download software from the Internet or use personal software programs on computers.

Please do not attempt to modify, gain access to files, passwords or data belonging to others, seeking unauthorized access to Four Winds or any other computer system or damaging or altering software components of any network or database.

Please do not use a Four Winds computer for commercial purposes or profit making.

Please do not attempt to circumvent data protection schemes or uncover security loopholes.

Please do not mask the identity of an account or machine; this includes, but is not limited to, sending mail anonymously.

Please observe all laws relating to copyright, trademark, export and intellectual property rights, as

well as any other applicable laws and regulations pertaining to use of Four Winds computers. Four

Winds is not responsible for any aspect of employees’ personal use of computers.

The display of sexually explicit images or sounds may create a hostile environment and could

constitute sexual harassment.

Four Winds computers are not intended for personal use and should not be used to transfer

financial and other personal data. Four Winds is not responsible for employee’s personal files or

data. Four Winds is not responsible for the misuse of personal information entered on websites.

Four Winds uses a Technology Protection Measure or a filtering service on all computers. However,

Four Winds cannot be accountable for information or images accessed through the Internet or

email. Employees are responsible for choosing which sites and content to access. The filtering

service disables access to certain web sites. Upon request to the IT Department, it may be

possible to unblock a site. Technology Protection measures are not 100% accurate and may allow

access to inappropriate sites.

September 1, 2015


ACES Guest Service

As a Service Ace, you’ve got a lot going on – all of your important responsibilities and a

casino full of guests here for a world class entertainment experience. ACES provides an

easy way to remember the little things that add up to great guest service. And great

guest service means everybody wins – our guests, Four Winds, and you.

APPRECIATE THE GUEST

SMILE – it’s #1 - everyone appreciates a smile

Use the guest’s name, introduce yourself, make a connection

Work 9 to 5 – eye contact at 9 feet; a friendly “hello” at 5 feet

Make the guest comfortable, check for satisfaction

CONSISTENTLY DELIVER QUALITY

Be ready for work; you never know when a guest will need assistance; if a

guest asks a question, you want to be knowledgeable

Look the part – enjoy yourself - you’re part of the world class experience

Follow policies and procedures for a consistently satisfying experience

EXCEED EXPECTATIONS

This is the big one – but it’s really the little things

Surprise the guest: remember their name, hold the door for them, don’t

just provide directions – walk them there

Provide a warm interaction and genuine, friendly service

Offer suggestions – sell the amenities

STRIVE TO BUILD LOYALTY

Sell the guest on the players club and current promotions

Thank the guest for joining us; wish them luck

Invite them to return

Genuinely enjoy our guests – we’re here because they’re here; we

appreciate their business; we want them to return and bring their friends

September 1, 2015


ACES Observation Score Guidelines

Great guest service means everybody wins – our guests, Four Winds, and you. The goal of

the ACES program is to create a culture that thrives on winning guest service. Remember:

APPRECIATE THE GUEST

Smile, use the guest’s name, work 9 to 5, check for satisfaction

CONSISTENTLY DELIVER QUALITY

Be ready for work, be knowledgeable, look the part, follow policies and

procedures

EXCEED EXPECTATIONS

Surprise the guest, provide a warm interaction and genuine, friendly

service, offer suggestions, sell the amenities

STRIVE TO BUILD LOYALTY

Sell the players club, thank the guest, wish them luck, invite them back

The ACES promise helps us accomplish our guest service goals. How well are you doing?

Our guests experience your signature service every day and build their loyalty on what

they experience from you and the entire Four Winds team.

We use a couple of methods for measuring how well we are meeting the ACES promise:

ACES Observation forms and Secret Shoppers. Positive results on your ACES

Observations contribute to positive performance evaluations. If you receive a score of

100% from a Secret Shopper, you can be rewarded through our ACES High program.

Our goal is for every employee to provide the best service possible. When this doesn’t

happen, it affects our guests’ experience.

If an employee receives a score lower than 75% of the total points on an ACES

observation or lower than 75% from a Secret Shopper, they will be asked to attend

an ACES refresher class for coaching on how to improve their guest service.

If an employee receives a score lower than 50% of the total points on either an

ACES Observation or a Secret Shopper, they will have 30 days to improve their

ACES score to 75% or better by both attending an ACES refresher class and

creating a performance improvement plan with their manager. If an employee is

unable to maintain acceptable service scores, further corrective steps may result.

As Four Winds’ Service Aces, we have a goal to provide great guest service 100% of the

time. Our customers know us and expect it. Why would we shoot for less?

September 1, 2015

A Read & Sign Flier for Managers - from the Training Department

Employment Records

Retention Guidelines

A Read & Sign for Four Winds Managers:

It is Four Winds policy to retain, for a period of one year, any records used in the

process of interviewing and/or hiring candidates or employees, including those being

considered for transfer or promotion. Those records include:

job applications,

resumes,

letters or any other form of employment inquiry submitted to the employer

during the interviewing or hiring process,

job orders submitted to any employment agency or labor organization for

recruitment,

test papers and results completed by applicants or candidates for any type of

aptitude considered in the hiring decision,

the results of any physical examination considered in the hiring decision, and

advertisements or notices to employees or to the public relating to job openings,

promotions, training programs, or opportunities for overtime work.

Please send any of the records identified above to the HR Office for retention.

If you have questions, contact the Director of Human Resources or a Human Resources

Manager.

Thank you.

September 1, 2015


Service Recovery Procedure

Slot Play TITO Theft or Loss

If a guest approaches you and says that their slot play Ticket In Ticket Out

(TITO) has been lost or stolen, or that a slot machine has shorted them, please do

the following:

1. Say, “Let me get someone to assist you”. Please, do not make any promises or

apologies other than to get assistance for the guest.

2. Contact Slot Dispatch by doing one of the following:

If the guest is at a slot machine, hit the call button to summon

assistance. Let the guest know that a Slot Floorperson will be there to

assist them shortly.

If the guest is not at a slot machine walk them to the Security Podium.

3. Once you have handed off the situation, circle back to ensure that someone

has responded to the guest.

A Slot Supervisor will respond, research the situation, and bring in management if

appropriate. Security and Surveillance will be called if necessary.

Our goal is to ensure our guests are provided the best possible ACES service.

Thank you for your help with this procedure.

September 1, 2015


Employee Entrance & Exit Policy

Four Winds employees are required to use designated employee entrances and

exits.

Approved employee entrances and exits in New Buffalo:

Main employee entrance at back of Casino

Parking garage ground level into Alley

Parking garage elevators into Alley

HR Building

o Front door (during business hours)

o Side door

o Facilities door

Not approved as employee entrances or exits:

Hotel front or back doors

Rotunda

Promenade

Loading dock into Alley

Loading dock doors

Approved employee entrances and exits at Hartford:

Main employee entrance at side of Casino.

Approved employee entrances and exits at Dowagiac:

Main employee entrance at back of Casino.

Please also note that all employees are subject to random searches of bags or

containers.

Thank you for your cooperation.

September 1, 2015


Responsible Gaming Guidelines

Four Winds has an ongoing commitment to responsible gaming. Please note:

It is important that we never discuss a guest’s personal information with anyone but

that guest. If a friend or family member of a guest wants to discuss a concern

with you, refer them immediately to the hotline telephone number on our

responsible gaming brochures. The hotline # is 1-800-522-4700.

Also, please remember these guidelines:

If you notice a guest with red flag behaviors, such as falling asleep, personal

neglect, or extreme anxiety or irritability, notify your supervisor, manager or

Security. Do not approach the guest directly. If a guest asks you for help with a gambling problem, refer the guest to the hotline

telephone number on our brochures, and tell your supervisor, manager or Security.

The hotline # is 1-800-522-4700. If a guest asks to be voluntarily excluded from gambling at Four Winds, follow this

procedure:

o New Buffalo casino: Refer the guest to the Gaming Commission. Please

escort the guest to Security. Security will escort the guest to the Gaming

Commission or provide the Gaming Commission’s telephone number, which is

1-269-926-5495.

o Satellite casinos: Refer the guest to the Shift Manager on duty. The Shift

Manager will provide the guest with the form to complete, and will forward

the form to the Gaming Commission. These are personal and confidential issues. Please follow the guidelines above with

compassion and confidentiality.

It is important to note that only the Gaming Commission or designated members of

Four Winds Senior Management are authorized to discuss a gambling concern with a

guest.

September 1, 2015, A Read & Sign Flier from the Training Department

Green: Guest is sober.

Encourage food, coffee and water. Food high in fat could help slow down the rate at which alcohol

is absorbed into the

bloodstream.

Yellow: Guest is becoming intoxicated. Wait for the guest to

reorder. Advise a manager to do a ”coffee talk” to help them slow down and enjoy their

evening.

Red: Guest is intoxicated.

Notify manager or security. Guest is not allowed to continue to game. Security will

arrange for alternate transportation.

CARE: Controlling Alcohol Risks Effectively

We are in the entertainment business and our guests come here to have fun. The CARE philosophy – Controlling

Alcohol Risks Effectively - helps us work together as a team to promote responsible alcohol consumption and

provide a great guest experience at the same time. A few reminders:

It is illegal to serve alcohol to minors (under 21) and intoxicated people.

Check the ID of anyone who appears to be under the age of 30. The ID must have a photo, date of birth,

signature and valid expiration date. Everyone is responsible to watch for minors; get your Manager or

Security if you need help. Double check guests with wristbands when serving or selling alcohol.

Anyone who serves alcohol can be sued, arrested, fined, sentenced to jail and/or lose his or her job for

serving alcohol irresponsibly.

Talk with guests as they arrive to discover who may be more likely to become intoxicated. You may also be

able to tell if the guest has been drinking prior to coming to Four Winds.

Here are some signs of intoxication to watch for to help keep our guests safe:

Relaxed Inhibitions Impaired Judgment Slowed Reaction Time Decreased Coordination

Personality changes Suddenly complaining about

drink strength, preparation

or price.

Glassy, unfocused eyes, dilated

pupils.

Difficulty handling coins, chips or

pulling money out of wallet.

Quiet guests becoming overly

friendly.

Drinking faster, ordering

doubles or shots

Drowsiness Clumsiness, such as spilling drinks.

Outspoken guests becoming

withdrawn.

Careless with money, leaving

purses or wallets

unattended.

Loss of concentration, inability to

finish sentences.

Loss of balance, staggering, bumping

into people, furniture or walls.

Falling down.

Noisy/rowdy behavior, suddenly

using foul language or making

offensive comments.

Starting arguments or

fights.

Altered speech patterns.

Difficulty lighting cigarettes or

having two lit at once.

Falling asleep.

Traffic Light System:

September 1, 2015, A Read & Sign Flier from the Training Department

CARE: Controlling Alcohol Risks Effectively

Guests are not allowed to leave the property with purchased alcoholic beverages. Politely confiscate or

notify a Manager or Security.

Guests are not allowed to bring in their own alcoholic beverages. Be on the lookout for alcoholic beverages

that are not sold here at Four Winds.

Remember that we need to handle each guest respectfully during “coffee talks” and “cut offs” and ensure

that they will be comfortable returning to the casino in the future.

We want to make our known players feel as comfortable as possible. Shift Managers and Casino Hosts know

our players well and have built relationships with them and will be called in to assist in both “coffee talks”

and “cut offs” with known players. This could help turn an uncomfortable situation for the guest into a

relatively positive one.

Steps to be taken for a “coffee talk”.

o Employee notifies Supervisor that guest is becoming intoxicated.

o Beverage Supervisor observes the guest for signs of intoxication.

o Determination of time frame to be served only non-alcoholic beverages is made by the Beverage

Supervisor. Usually 2-4 hours.

o Beverage Supervisor contacts Surveillance for coverage.

o Beverage Supervisor works with Shift Manager or Casino Host (depending on guest location) to

determine if the player is known. Shift Manager or Casino Host may assist Beverage with speaking

to the guest.

o Beverage Supervisor communicates to all Beverage Employees a description of the guest and how

long the “coffee talk” is in effect.

o Guest is allowed to continue gaming and is observed by appropriate staff.

Steps to be taken for a “cut off”.

o Employee notifies Supervisor that guest is intoxicated.

o Beverage Supervisor observes the guest and confirms intoxication.

o Beverage Supervisor will contact Security MOD. Security will contact Surveillance.

o Beverage Supervisor works with Shift Manager or Casino Host (depending on guest location) to

determine if the player is known. Shift Manager or Casino Host may assist Beverage with speaking

to the guest.

o Guest is then introduced to Security MOD and removed from the Gaming Area for a minimum of 8

hours. Guest is not allowed to continue gaming. Security will make arrangements for the

guest to find alternate transportation.

Only 1 -2 people should approach the guest during a “coffee talk” or “cut off”.

The Beverage Department has the final say on all “coffee talks” and “cut offs”. Please continue to support

the decisions of the Beverage Department.

If a supervisor or manager makes the call to deny service to an intoxicated guest, Security will escort the guest to

safe transportation or to one of our restaurants for food and coffee and the opportunity to continue to enjoy

their experience at Four Winds. Under no circumstances will an intoxicated guest be allowed to drive.

September 1, 2015


Social Media Technology Policy

Four Winds respects its employees’ decisions to use social media technology; however, depending upon

the circumstances, it is possible that readers of a site might view the employee as a representative or

spokesperson for Four Winds, or might form views about Four Winds which are inconsistent with our

image. Therefore, as a condition of employment, we require that you comply with this policy when using

social media technology, especially when referring to any aspect of your employment, including other

employees, or our ownership, the Pokagon Band of Potawatomi Indians.

Social media is the term used to describe a range of online tools that people use to communicate,

including, but not limited to:

• Blogs (web-based journals);

• Social and professional networking sites (e.g., MySpace, FaceBook, LinkedIn, Twitter, etc.);

• Message boards;

• Wikis (collaborative websites, e.g., Wikipedia);

• Video sharing (e.g., YouTube); and

• Podcasts (multimedia files distributed over the internet).

Post as Yourself. Make clear that you are expressing your personal views alone. Make certain that your

views could not be attributed to Four Winds or any of its other employees. In some cases, the following

statement may be appropriate: “The material on this site is my own and does not necessarily represent

the view of my employer.” You assume full responsibility and any liability for the content of your

postings.

Be Respectful. You must be respectful in all social media communications related to or referring to Four

Winds, its employees, its management company, its owners, its business contacts, or its competitors. You

must not post communications or material that is disparaging, bullying, threatening, or inappropriately

inflammatory. While you are welcome to disagree with others, your social media communications related

in any way to Four Winds must be respectful.

Comply with Harassment and Other Policies. You may not use social media technology to post

communications or material that would violate any Four Winds’ policies, including, but not limited to, our,

Employee Handbook, Employee Code of Conduct policy, Confidentiality policy, Harassment &

Discrimination policy, and Conflict of Interest/Business Ethics policy. You may not post communications

or materials that are derogatory or offensive with respect to race, religion, gender, sexual orientation,

national origin, disability, age, or any other legally protected class status.

Keep Secrets. You must not disclose Four Winds’ confidential proprietary information or trade secrets

through social media or otherwise. If you have any doubts regarding the confidentiality of any

information, you should either obtain written permission from your supervisor to post the information or

err on the side of keeping the information confidential.

Don’t Steal. Four Winds owns intellectual property rights in its trademarks (name and logos), advertising

material, corporate communications, and other documentation. You may not use or disclose intellectual

property online without advance, written permission. In addition, you may not post photos relating to

employees, customers, or business contacts without obtaining advance, written permission from your

supervisor and the individuals in the photo.

September 1, 2015


Use Good Judgment. Because what you say online is accessible to the public, including Four Winds and its

employees, use good judgment in your communications. Ask yourself, is this something that I would want

my supervisor, coworkers, management company or ownership to see? We all contribute to the

reputation of Four Winds and its brand, and we must insist that you refrain from activity that could

reflect negatively on Four Winds. If you are even the slightest bit uncomfortable about a possible

posting, review the rules in this policy and think about why you are uncomfortable and whether you

should post the material.

Obey the Law. This goes without saying, but, as a reminder, do not post any material that violates the

law, such as material that is defamatory, threatening, harassing, or that violates the privacy rights of

someone else. Also, do not post any material that may contain a computer virus. In addition, if you are

using material authored or created by someone else, obtain permission first and give them credit.

Don’t Expect Privacy. Because your social media communications are publicly available, you should not

expect that your communications are private in any way or that Four Winds will not access and review

your communications. Be mindful that your postings will exist in the public forum for a long time, and do

not post anything that you wish to keep private.

Ask for Guidance. If you have any questions about what is appropriate to include in social media

communications, ask your supervisor.

Employees who violate this policy may be subject to discipline, up to and including termination of

employment.

Thank you for your support of this policy.

September 1, 2015

A Read and Sign Flier from the Training Department

Title 31

Key Definitions to Remember

Title 31 is a Federal requirement under the Bank Secrecy Act of 1970 that all casinos report to

the Treasury Department any cash-in or cash-out transactions of more than $10,000 within a

gaming day. It is a program that protects the casino from money laundering and use of illegally

obtained funds.

Terms you should know

MTL - Multiple Transaction Log. A Four Winds Form used to log a patrons cash

transactions beginning at $3,000 that, may exceed $10,000 during a 24-hour period.

FinCEN CTR – Currency Transaction Report is a document that is completed when a

patrons financial transaction exceed $10,000.

FinCEN SAR – Suspicious Activity Report is used to document suspected violations of law

or suspicious activity beginning at $5,000.

W-9 – A legally binding government form that allows us to accept a verbal social security

number without verifying documentation.

Four Winds Gaming Day

4:00am – 3:59am -The normal business day of the Casino by which it keeps its books and

records for business, accounting, and tax purposes. This information is confidential and

should not be shared with guests.

Title 31 Crimes

• Agent – Someone who acts on behalf of someone else.

• Structuring – occurs when a guest or guests intentionally keep their cash transactions

below Title 31 reporting levels. Example: Patron intentionally is breaking up larger

transactions into smaller transactions.

Penalties employees can receive if they willfully violate Title 31:

• Civil penalties up to $100,000 and Criminal penalties up to $500,000 and/or imprisonment

up to 10 years

September 1, 2015


Please Remember:

Verify valid, Federal or State issued photo ID. An expired ID is not a valid form of

identification.

You should report suspicious activity to your department supervisor. Examples of

suspicious activities include, but not limited to:

o Requesting to know the gaming day of the casino

o Intentionally trying to avoid FinCEN CTR requirements

o Large buy-ins with minimal play

o Using false identification

o Inserting large bills into a slot machine with minimal play

Slots Only:

If a patron is inserting large amounts of hundred dollar bills and pressing the cash out

button with minimal play, a FinCEN SAR should be filled out.

If a patron presents a passport from Mexico during a jackpot payout, this would be

considered a foreign jackpot.

September 1, 2015


Hazardous Communication

Keeping Employees Safe

As an employee of Four Winds you have a need to know about the hazards of chemicals you

may be exposed to when working. You also need to know the protective measures to use to

prevent an exposure incident.

Goals of Hazardous Communication are:

To help you reduce the risks involved in working with hazardous materials

To transmit vital information to employees about real and potential hazards of substances in

the work place

To reduce the incidents of illness and injury resulting from hazardous substances

To encourage a reduction in the volume and toxicity of hazardous substances

There are two kinds of hazards associated with chemicals:

Health Hazards: Can cause illness or injury. Example: Skin irritation, lung damage, nausea, dizziness.

Physical Hazards: Condition in the environment. Example: Flammable or explosive chemicals.

Chemicals can enter your body through absorption, inhalation or ingestion.

Safe Work Procedures:

Use chemicals properly and only for their intended use

Do not mix chemicals

Use appropriate Personal Protective Equipment (PPE)

Safety Glasses/Goggles Uniforms/High Visibility Clothing

Gloves Boots/Slip Resistant Shoes

Aprons Face Shields

Know what PPE to wear for different chemical hazards!

When in doubt, ask your supervisor!

Seven steps to proper Lifting

1. Size the object

2. Feet should be shoulder

width apart

3. Bend with your knees push up

with your legs

4. Keep your back straight as

you lift

5. Get as close to the object as

possible

6. Get a good firm grip with

your hands

7. Remember to move your feet

when you turn, do not twist

your back!

September 1, 2015


Bloodborne Pathogens

Bloodborne pathogens are infectious microorganisms present in blood that can cause

disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV),

hepatitis C virus (HCV) and human immunodeficiency virus (HIV), the virus that causes AIDS.

Workers exposed to bloodborne pathogens are at risk for serious or life-threatening illnesses.

Ways to keep yourself safe:

Treat all blood and bodily fluids that may contain blood as if they are

contaminated.

Use proper personal protective equipment (PPE), such as gloves, eye protection,

and masks.

Hepatitis B vaccinations are available to all Four Winds employees through the

Wellness Center. Four Winds provides Hepatitis B vaccinations free of charge

to employees that work in Facilities, Transportation, Room Attendants, Slot

Technicians, and Security.

If there are no infiltrations of mucous membranes or open skin surfaces, it is

not considered an occupational exposure.

Report all accidents involving blood or bodily fluids to Security or a Supervisor.

Safety Data Sheets (SDS)

Safety Data Sheets are the primary document by which health and safety information is provided.

All SDS’s vary but must have the following information included:

Product Information Fire and Explosion Hazard Data Precautions for Safe Handling

Hazardous Ingredients Reactivity Data Control Measures

Physical Properties Health Hazard Data

Employees must know where SDS sheets are located. If you do not know, ask your Supervisor!

September 1, 2015


Password Policy

BACKGROUND – In many systems, passwords are the first and only line of defense. In a multi user-

computing environment the actions of one user can affect other users on the system. Therefore,

breeches in security can and do affect the productivity of all system users on the system. The

Information Technology Security Policies will, if followed, go toward protecting and authenticating data

and system resources. Much has been written about hackers and white-collar theft via the environment,

many programs have audit trails that are keyed to the user’s logon ID. As these audit trails are referred,

the ultimate responsibility for updates and changes will rest upon the user whose ID is shown as the last

one changing the data. This policy should address the issues of data safety and data responsibility.

INTENT - This policy shall refer to passwords and data files on any computer system in use at Four

Winds. These systems include, but are not limited to, the Local Area Network, any extensions of these

systems, or stand alone computer equipment, which is used to support the operation of the company. The

intent of these policies is to insure the integrity of the data system by enforcing the data access

limitations governed by each user logon ID. It is also the purpose of this policy to protect the entire

system from unauthorized access by any individuals who would want to corrupt the companies’ data for

either fun or profit.

POLICIES - Each user will have a logon ID and password to access any computer system at Four Winds.

The Information Technology Department will be responsible for issuing a user ID and password to all

users on the LAN. The Information Technology Department will then show the user how to change their

passwords.

PASSWORDS – Each user should have and use a password. The Information Technology Department will

require all users to have and maintain passwords on all systems. The Information Technology Department

will assign users who do not have a password. The user may change their own password. Passwords on the

local area network will be automatically changed every 45 days. All passwords should be immediately

changed after any person learns the user’s password. Each user will be prompted at appropriate intervals

to change their password. It is the user’s responsibility to maintain and safeguard their password.

Necessary access to another person’s data files may be granted without compromising a user’s password.

Therefore, the Information Technology Department personnel will not give out user passwords.

PASSWORDS RECOMMENDATIONS – All user-chosen passwords must be difficult to guess. Words in a

dictionary, derivatives of user-IDs, and common character sequences such as “1234567” are not

recommended. Likewise, personal details such as spouse’s name, license plate, social security number, and

birthday are not recommended unless accompanied by additional unrelated characters. Suggestions for

constructing a difficult-to-guess yet easy to remember passwords: (1) string several words together, (2)

shift a word up, down, left or right one row on the keyboard, (3) bump characters in a word a certain

number of letters up or down the alphabet, (4) transform a regular word according to a specific method,

such as making every other letter a number reflecting its position in the word, (5) combine punctuation or

September 1, 2015


numbers with a regular word, (6) deliberately misspell a word- but not a common misspelling, or (7)

combine a number of personal facts like birth dates and favorite colors.

BREECH OF PASSWORD SECURITY - If the Information Technology Department learns of a shared

password or a breach of password security, the user’s ID will be suspended until such time as the user’s

supervisor, an Information Technology representative, and the user can discuss the situation to

determine a mutually acceptable solution. After 3 breaches of password security occur, the user shall be

recommended for disciplinary action in accordance with the employee manual. It is the user’s

responsibility to maintain and safeguard their password. The Information Technology Department will not

give out user passwords.

DEVIATIONS - If it is necessary for others to have access to an individual’s files, arrangements can be

made to provide the necessary access without compromising a user’s password. Access to another

person’s files requires either the file owner’s written permission or the file owner’s supervisor’s written

permission. If the Information Technology representative feels there is cause to deny access, the file

owner’s supervisor will make the final decision.

September 1, 2015


Minors/Under 21 Policy

With a commitment to responsible gaming, Four Winds welcomes guests 21 years of age

and older to game in our Casinos. Minors are welcome in specific venues on property when

escorted by an adult, but are prohibited from gaming activity, consuming alcoholic

beverages, lingering in the gaming area, or being left unattended.

Four Winds New Buffalo Casino:

Minors (under the age of 21) are welcome when accompanied at all times by an adult

(over the age of 21).

Minors are not permitted to game or linger in any gaming area.

When on the casino gaming floor, minors and their accompanying adults will use main

pathways and move toward their destination without stopping to use an ATM,

beverage self-serve, the Cage, bars, or W-Club.

Minors and accompanying adults are welcome from 7am to 11pm in:

o Hard Rock Cafe, Timbers, Grab N’ Go Kiosk, Silver Creek Event Center, and

the restrooms on the casino floor.*

Minors and accompanying adults are welcome during normal hours of operation in:

o The Hotel, The Buffet, retail outlets and restrooms along the promenade.

Copper Rock and the Player’s Lounge welcome guests over the age of 21. Minors may

be pre-approved by Senior Management.

Guests over the age of 21 may reserve a hotel room. Minors will be accompanied by

an adult at all times when in a hotel room.

Kids Quest provides hourly child care for children 6 weeks to 12 years of age.

Cyber Quest is available for children of all ages, but children under the age of 12

must be accompanied by an adult.

Four Winds Hartford and Dowagiac Casinos:

Guests over the age of 21 are welcome in the satellite casinos.

Minors must be attended at all times while in vehicles in any of Four Winds’ parking lots.

All Four Winds employees are asked to assist Security in implementing this policy.

Note: These restrictions do not apply to Four Winds employees under the age of 21 while

on duty.

*Minors may be excluded from events held at Hard Rock Café or Silver Creek Event

Center that are considered to be 21 and over entertainment acts.

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HARTFORD | DOWAGIACNEW BUFFALO