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Gaming Policy and Enforcement Branch

August 15, 2013 of 50

Gaming Enforcement Action – Electronic 50/50 Ticket Raffles Gaming Service Providers and Charities This document provides an overview and chronology of events related to enforcement actions by the Gaming Policy and Enforcement Branch (GPEB) affecting providers of electronic 50/50 ticket raffle systems in British Columbia and the charities that use them. The events mentioned in this document occurred in 2012 and resulted in changes to GPEB’s registration, certification and licensing requirements, as well as enforcement actions.

In this document: 1. Introduction .................................................................................................................. 2 2. Background .................................................................................................................. 2 3. The Issue ..................................................................................................................... 3

BUMP 50/50 System Failure ......................................................................................... 3 5050 Central System Failures ....................................................................................... 4

4. The Results .................................................................................................................. 5 5. Contact Information ...................................................................................................... 6 Appendix A: Compliance Audit - Canucks for Kids Fund (September 1, 2011 to

June 30, 2012) ........................................................................................... 7 Appendix B: Event Inspection - Canucks for Kids Fund (January 19, 2013) ..................... 14 Appendix C: Event Inspection - BC Lions Football Club (October 29, 2012) ..................... 18 Appendix D: Letter - Canucks for Kids ............................................................................ 23 Appendix E: Letter - BC Lions ........................................................................................ 26 Appendix F: Letter - Kamloops Blazers ........................................................................... 29 Appendix G: Letter - Curl BC .......................................................................................... 32 Appendix H: Letter - Rycom ........................................................................................... 35 Appendix I: Letter - Pointstreak ...................................................................................... 38 Appendix J: Letter from Doug Scott, GPEB General Manager and Assistant Deputy

Minister (January 10, 2013)....................................................................... 41 Appendix K: Canucks for Kids Fund Open Letter ............................................................ 44 Appendix L: Certificate of Technical Integrity - Bump 50:50 ............................................. 46 Appendix M: BC Lions Football Club Raffle Licence - Percentage Draw........................... 48


Gaming Enforcement Action – Electronic 50/50 Ticket Raffles Gaming Service Providers and Charities

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1. Introduction The Gaming Policy and Enforcement Branch (GPEB) regulates all gambling in British Columbia, ensures the integrity of gaming industry companies, people and equipment, and investigates allegations of wrongdoing. These responsibilities include the licensing and auditing of gambling events conducted by community organizations to raise money for eligible programs. In 2012 issues were discovered related to electronic 50/50 raffle systems employed in the province at this time. Throughout the fall of 2012, GPEB actively worked with many stakeholders on this issue including, the Canucks for Kids Fund, BC Lions Community Fundraising Group, Kamloops Blazers Scholarship and Education Society, Curl BC, Bump 50:50, and Pointstreak 5050 (formerly 50/50 Central). This chronology is added as part of GPEB’s open information to provide context for an unusually complex situation. 2. Background Licensed gambling events include 50/50 raffles conducted by large and small sports groups. It is important that a raffle be conducted fairly so that everyone who buys a ticket (or tickets) has an equal opportunity to win. New technology has enabled sports teams to use electronic equipment instead of the rolls of paper tickets used in the past. (Paper tickets are still used at many events.) When using an electronic system, the seller uses a remote sales unit consisting of a tablet (for inputting number of tickets bought, and for determining the total price) and a mobile ticket printer. The buyer gets a single ticket showing draw numbers purchased. Draw numbers are transmitted electronically to a bank of central printers that print and deposit the ticket directly into a draw barrel. The winning ticket is drawn by hand out of the barrel. The person who bought the ticket with the winning number receives half the proceeds of the draw and the charity receives the other half. The electronic systems are used only to sell and print tickets. They are not involved in determining the winning number, nor do they pay out directly to the player. As a result, GPEB originally considered the equipment and software to be point of sale equipment that did not require certification. Similarly, nor did the companies providing the technology need to be registered. The two largest 50/50 raffles conducted by sports teams in British Columbia are those run by the National Hockey League’s Vancouver Canucks and the Canadian Football League’s BC Lions. By conducting 50/50 draws at their home games, the Canucks support the Canucks for Kids Fund (CFKF) and the Lions support the BC Lions Community Fundraising Group. The electronic 50/50 equipment used by CFKF is Bump 50:50 (parent company: Rycom Management Corporation). The BC Lions use Pointstreak 5050 (parent company: Pointstreak Sports Technologies Inc.).



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3. The Issue The following is a summary of problems that arose with some electronic 50/50 draws conducted by the Canucks and the Lions. Also described is the resulting action taken by GPEB to ensure the integrity of licensed gambling in B.C. BUMP 50/50 System Failure During an Aug. 3, 2012, meeting to discuss the logistics of a GPEB Information Technology (IT) audit, CFKF disclosed a major malfunction that took place during a raffle at a Canucks game on April 22, 2012. A technical issue (cellular communication was lost between the sales tablets and the printers) prevented the printing of some 50/50 tickets sold. These tickets were not placed in the draw barrel. At the time, CFKF thought that perhaps 10,000 tickets might be missing. They made the decision to conduct the draw. GPEB auditors requested that CFKF complete a formal incident report and a routine Information Technology (IT) report by Aug. 17, 2012 to detail the situation. GPEB informed CFKF that the delay in reporting the malfunction contravened Section 2.2 of the Guidelines: Applying for a Class A or B Event Licence. On or about Aug. 31, 2012, GPEB told CFKF that they must suspend the use of Bump 50:50 technology until an independent test lab could review the technology, and all concerns were satisfied. GPEB made the decision that the electronic technology, while point of sale equipment, still had the potential to affect the integrity of the draw as demonstrated. They therefore determined that electronic 50/50 systems would require certification, and that the system providers would be registered. During early deliberations regarding the situation, GPEB noted that CFKF’s previous compliance record was exemplary and further decided that:

• GPEB would work with CFKF and Bump 50:50 to resolve the technical issues if possible;

• Complete information would be gathered in order to determine an appropriate response to CFKF’s failure to report the incident in a timely manner;

• There was a duty to inform Vancouver Canucks fans of this occurrence in advance of CFKF conducting another 50/50 draw; and

• GPEB should investigate the other electronic 50/50 system operating in the province to ensure it is sound and the public was not at risk.



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5050 Central System Failures Because of the problems with the electronic 50/50 system at Vancouver Canucks hockey games, GPEB immediately began an investigation of the other electronic service provider, Pointstreak 5050 to ensure the integrity of that system. Jurisdictions across Canada where 50/50 Central was in use were contacted, to determine if there was evidence of similar system failures with this technology. In addition, GPEB auditors attended the next three BC Lions football games, as well as a Kamloops Blazers game, to observe and evaluate the draws. During the September 8th

game, auditors found Pointstreak 5050 technology encountered a problem with its cellular communication. The problem was mitigated by having stationary purchase terminals hard wired into the stadium network, and the draw proceeded successfully. Despite successful resolution of the technical issue at the Sept. 8, 2012 game, GPEB determined that continued monitoring was appropriate.

In early September GPEB met with CFKF, at which time the charity stated they believed that more than 20,000 tickets [out of 85,000 sold] failed to make it into the draw barrel on April 22, 2012. A week later a revised technical report, requested by GPEB and provided by Bump 50:50, revealed that 43,333 tickets did not make it into the draw barrel on April 22. Details are included in two GPEB audit reports:

• Compliance Audit - Canucks for Kids Fund (September 1, 2011 to June 30, 2012)

• Event Inspection - Canucks for Kids Fund (January 19, 2013)

At a subsequent meeting GPEB discussed the requirement for CFKF to disclose the April 22 malfunction to the public before the next Canucks game. (On Sept. 15, 2012, the NHL announced a lock-out of its players. The Canucks first game of the 2012/13 season was a home game on Jan. 19, 2013.) At the Sept. 15, 2012 Vancouver Lions game, GPEB noted that procedural problems meant that the winning ticket was announced before it had been validated. The winning ticket was subsequently validated. GPEB decided to complete a full reconciliation of all tickets sold at the BC Lions game on Oct. 19, 2012 GPEB auditors noted both technical problems and human errors. (Details are included in a GPEB audit report.) On Oct. 25, 2012, GPEB suspended the use of both electronic 50/50 raffle systems for all charities in B.C. while the systems were tested by an independent test lab (Gaming Laboratories International [GLI]). The full reconciliation was completed, and GPEB found that there were two tickets listed as sold and printed, but were never found. On Nov. 13, 2012, GPEB sent letters to those licensed to use electronic 50/50 systems, to provide an update on the progress of system testing. The letters informed them that the operating issues included operator training and raffle facilities, that future licences would be subject to new conditions and that 50/50 raffles could continue to be conducted using manual



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paper tickets. Letters were sent to the Canucks for Kids Fund, BC Lions Community Fundraising Group, Kamloops Blazers Scholarship and Education Society (whose electronic 50/50 raffles had run without issue) and Curl BC (who had expressed interest in using electronic systems to conduct their charity draws), and to the two companies involved (Rycom Management Corporation, parent company of Bump 5050; and Pointstreak Sports Technologies Inc., parent company of 5050 Central). The letters are available at the following links:

• Letter - Canucks for Kids

• Letter - BC Lions

• Letter - Kamloops Blazers

• Letter - Curl BC

• Letter - Rycom

• Letter - Pointstreak

4. The Results Discussions took place between GPEB and CFKF regarding the method and timing of disclosure to the public of the April 22, 2012 malfunction, concluding with a January 10, 2013, letter from Doug Scott, GPEB General Manager and Assistant Deputy Minister following the announcement of the season schedule. Mr. Scott directed in his letter that CFKF would post an open letter on the Canuck’s website on January 10 and email the letter to Canucks newsletter subscribers on Jan. 16, 2013. The open letter was posted on the Canucks website in the news section. When the Canucks newsletter was emailed to subscribers six days later, the newsletter did not include the open letter but instead provided a link to the letter. On Jan. 11, 2013, GPEB advised CFKF that the Bump 5050 system was certified for use (certificate). GPEB auditors attended the first Canucks game of the season, to ensure the system functioned properly. On March 1, 2013, 5050 Central, the electronic 50/50 raffle technology used by the BC Lions (and potentially other licensees) was certified for use. On July 2, 2013 an amended licence was issued to the BC Lions to conduct 50/50 raffles using the Pointstreak 5050 system for the period from June 21, 2013 to Nov. 17, 2013. At each of two Canucks games in April 2013, system malfunctions occurred and CFKF reported the issues promptly to GPEB as required. On April 8, two electronic raffle ticket holders reported to raffle staff that they were sold the same ticket numbers with the same time stamp. GPEB auditors spoke with the charity, and also referred the matter to GPEB’s technical experts. As a result, GPEB once again suspended the use of Bump 50:50. GPEB attended the Lions game on July 4, 2013 and noted no issues threatening the licence.



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On July 18, 2013, GPEB certified the Bump 50:50 system on an interim basis having determined the technical cause of the error and being satisfied with the resolution employed by the service provider. The interim certification is conditional on GPEB checking the system again prior to the 2013/14 NHL season. Full certification will depend on the inspection and the success of raffle operations at Vancouver Canucks home games through November 2013. To view other charitable audit reports which may be of interest, please visit the GPEB Audit Reports page and click on “Registered ticket raffle licensee audits”. 5. Contact Information Gaming Policy and Enforcement Branch 3rd Floor, 910 Government Street Victoria, BC V8W 1X3

Telephone: 250 387-5311 Web: www.gaming.gov.bc.ca E-mail: [email protected]

http://www.gaming.gov.bc.ca/reports/audits.htm�

http://www.gaming.gov.bc.ca/reports/audits.htm�

http://www.gaming.gov.bc.ca/�

mailto:[email protected]�



August 15, 2013 of 51

Appendix A: Compliance Audit - Canucks for Kids Fund

(September 1, 2011 to June 30, 2012)

of 6 Audit and Compliance Program

This report is the property of the Audit and Compliance Division of Gaming Policy and Enforcement Branch and is not intended

for use or circulation beyond specified recipients without the permission of the Director of Audit and Compliance, Gaming Policy

and Enforcement Branch. The audit is limited to the evaluation of compliance with Branch policies and procedures and the

findings express no opinion on the financial statements. The findings in our final report may set forth instances of non-

compliance with the Gaming Control Act, Regulation, and/or other Branch policy documents. While instances of non-compliance

may jeopardize ongoing eligibility for gaming access, eligibility is determined solely by the Licensing and Grants Division, which

will receive a copy of this report.


Charitable Gaming Audit and Compliance

REPORT OF COMPLIANCE AUDIT FINDINGS

REGISTERED RAFFLE

Date: Feb. 26/13

Prepared By: Auditor

Reviewed By: Reviewer

Licensee : Canucks for Kids Fund Licence #: 35972

Org #: 103204 Char #: 7029 Licence Period: Sep. 1/11 to Jun. 30/12

Type of Review: Compliance Audit

Type of Gaming Access: Licensed Gaming – Registered Raffle

Sector: Human and Social Services

Scope: Limited Review (Review did not encompass testing of system controls or functionality of electronic

system).

Gaming Activity: Per GERR As Audited

Gross Revenue

Total sales $ $

GST recovery $ $

Other gaming revenue $

Interest income $ $

Total Gross Revenue $ $

Prize Costs

Cash prizes $ $

Cost of merchandise prizes

Total Cost of Prizes $ $

Donated prizes

Event-Related Expenses

Advertising costs

Wages $ $

Facility rental related to the gaming event

Contract fees for gaming services providers $ $

Printing costs $ $

Postage and mailing costs

Miscellaneous supplies for the gaming event $ $

Bank charges $ $

Other $ $

Cash (over)/short

Total Event-Related Expenses 420,201.00$ 420,201.00$

Expenses as a percentage of gross revenue 11.64% 11.64%









Audit Findings

During the period reviewed, our audit work relative to the conduct and management of the Registered

Ticket Raffle established the following instances of non-compliance and all discrepancies pertaining to

advertising and marketing media (regardless of materiality). Issues below are based on a sample chosen

from the total event population. The dates sampled were the date attended for an event inspection and two

subsequent events. The sample was extended by comparing the system reported sales to sales deposits, to

determine any unusual variation.

1. Tickets sold were not reliably recorded and processed by the sales system. On February 13, 2012 sales

reported by the system did not reflect seller’s total cash. Per system’s report, sales were $45,065 while

cash collected was $51,249.32. The $6,184.32 difference could not be attributed to the tickets

recorded in the database. Although assurance was given by the system’s service provider, BUMP,

based on their access to the database, that all tickets were printed to the barrel, supporting evidence

was not provided.

On April 22, 2012 a failure in the electronic 50/50 system resulted in 43,333 tickets (out of 76,825

sold tickets) not being entered into the draw. The organization has since posted an open letter on its

website notifying the public of the incident.

2. The event irregularity of April 22, 2112 was not reported to GPEB in a timely manner. The incident

was reported on Aug. 3, 2012.

Section 2.2 of the Standard Procedures for Ticket Raffles states, in part, that “Section 86 (2) of the

Gaming Control Act (GCA) requires all licensees to notify GPEB’s Investigations and Regional

Operations division without delay regarding any conduct, activity or incident that may be considered

contrary to the Criminal Code of Canada, the Gaming Control Act or Gaming Control Regulations, or

that may affect the integrity of gaming.

3. At the time of the draw, tickets are verified against the sales database to determine eligibility. Per the

system’s service provider, not all data of tickets sold on February 13, 2012 reached the database. As a

consequence, a valid ticket may have been considered invalid during the verification process.

Section 12.1 of the Standard Procedures for Ticket Raffles states, in part, that “Before conducting the

draw, your organization must ensure that each sold ticket forms part of the draw.”

4. The ticket reprint process of tickets being printed into the barrel lacked controls to ensure accuracy.

We observed that tickets occasionally jammed in the printer in the process of being printed into the

barrel. The system’s service provider was contacted by licensee’s staff to generate a reprint of the

ticket(s) jammed. The following was noted with regards to the reprinting process:

The reprinting of tickets that entered the barrel depended on the first number jammed being









identifiable. If the first ticket jammed was not identifiable, the ticket(s) would not get

reprinted. The detail of reprint capabilities was not available during the licence period of

2011/12. For example, it is not clear if the reprint of a ticket that was part of a set would

include all the remaining tickets up to the end of the set, or if part of the set of tickets had been

re-routed to another printer, automatically, after the jamming of the first ticket.

The user did not have the ability to generate a report of reprinted tickets to barrel to provide an

audit trail to the tickets that had been actually reprinted.

Based on a manual report generated at the time of the audit by the system’s service provider,

BUMP, it appears that on February 15, 2012 jammed ticket number 425825405 was not

reprinted and so was not in the barrel when the draw occurred.

5. Voided ticket reporting was incorporated into the system on March 1, 2012. The following issues

were noted with regards to voided tickets as reported in the system:

Per the Ticket Reconciliation (system’s report: Bump Raffle Summary) a total of 1,921 tickets

were voided from March 1 to April 22. However, the actual number of voided tickets during

this period may be different. Total void tickets per manual licensee’s records on March 1st

and on April 22nd 2012 were compared to the sets indicated by the system’s report for the

same dates (Game Summary/Manager Panel) and the numbers differed.

The Ticket Reconciliation (Bump Raffle Summary) unit for void tickets was “ticket” not “sets”,

while the sales totals were determined by “sets of tickets.” This lack of detail did not provide

sufficient information to calculate the total sales voided.

Upon request during the audit, the licensee provided a manual break down of the 1,921 void tickets

reported by type of ticket sets sold and selling price by set, to calculate the dollar amount voided.

Section 8.3 of the Standard Procedures for Ticket Raffles states, in part, that “Licensees must also

maintain a written reconciliation, by selling price, of tickets sold.”

6. The Ticket Reconciliation (Bump Raffle Summary) was not generated (printed) at the time of the draw

on February 13 and April 22, 2012, because (a) it was not indicating accurate figures and, (b) it could

be printed at a later date. Comparison of numbers for two other dates indicated inconsistencies in

summary figures of the same events on reports printed at different dates/times, which makes the audit

trail unclear to the actual figures at the time of the draw. Generation of reports previous to the draw

provides a clear audit trail to any changes or manual entries for required adjustments.

Section 12.1 of the Standard Procedures for Ticket Raffles, states, in part, that “Before conducting the

draw, your organization must: Reconcile the number of sold tickets with the number of counterfoils in

the draw container, to ensure that only eligible tickets form part of the draw”

7. Various inconsistencies in the system’s reports did not provide sufficient and/or adequate audit trail to

validate summary figures. For example, the inconsistency in the units used for reporting tickets sold

(set) and units used for reporting void tickets (ticket), per issue 5, above. Also, there were

inconsistencies in the data of some event Ticket Reconciliations (system report: Bump









Admin/Manager Panel), for example:

February 13 (printed on Dec. 18/12 11:15am): The count for “Actual Mobile Tickets” and

“Actual Drum Tickets” should match after accounting for the reprints. However, there was an

unexplained difference of 12 tickets (36,265 vs 36,253), which indicates there may have been

12 more tickets printed into the barrel than actually sold.

February 18 (printed on Feb 18/12, 08:03pm), “Numbers sold” showed 94,233 tickets, but

“Tickets printed” showed only 8,322 tickets, with 742 “Printer errors”. “Tickets re-printed”

showed 70. Information about tickets printed, printed errors and tickets reprinted appears to be

inconsistent.

February 18 (printed on Nov. 30/12, 04:07pm): “Mobile Tickets” showed 95,022 tickets,

“Mobile Reprints“ shows 789, “Actual Mobile Tickets” shows, 94,233, while other fields such

as “System Tickets” and “Actual Drum Tickets” showed 0 count. Although the “Actual

Mobile Tickets” 94,233 figure is consistent with the “Numbers Sold” in listing printed on

February 18/12, 8:03pm, the mobile reprints figure of 789 is not consistent with either the

“Printed errors” or “Tickets re-printed” figures on the same date.

8. Per the Licensee, data for April 22 was reconstructed and entered in the system on May 17, 2012.

However, appropriate reversal entries for the erroneous data were not entered and the system contains

two sets of data for the same event. The system, having two active sets of data for the same event

caused Ticket Reconciliation reports (Bump Raffle Summary) to show different summary results due

to different selection criteria. Not entering the appropriate reversal information (or transferring to

archives or showing the data as inactive) places onus on the user to remember to manually adjust the

criteria for the special circumstance around an event in order to produce accurate figures in reports.

9. The system design requires sellers to press the [Print to Drum] button separately, after the mobile

printer generates a ticket. The seller also has the option to press [Reprint] to print a new set of tickets,

with different numbers. The purpose of the [Reprint] feature is to generate a new ticket, when a ticket

did not print successfully on the mobile printer. However, it appears that sellers were able to reprint

tickets, even if no printer error occurred. This may result in two (or more) tickets with no identifying

features as to which tickets are valid and which are not. A ticket purchaser cannot verify whether the

ticket he purchased is valid (Printed to Drum), or invalid (Reprinted), if a seller were to try to misuse

the system and appropriate the funds.

10. A revenue category was inaccurately reported. On February 13, 2012, Canucks for Kids obtained

$ compensation from the system provider, BUMP, for having to stop sales at an earlier time

due to system issues. The compensation amount was reported as “Sales” on line 1 of the Gaming

Event Revenue Report. It should have been categorized separately on the Gaming Event Revenue

Report, or with a disclosing note.

11. The following issues relating to cash management were observed during the course of the review:

Sales proceeds (ranging from $10,000 – $50,000) were not always deposited to the gaming

account in a timely manner after each event. Examples:

(a) March 1, 2012 sales proceeds were deposited on March 7, 2012.









(b) March 10, 2012 sales proceeds were deposited on March 16, 2012

$ to February 13, 2012 sales was deposited on February 17, 2012. These were funds

taken home, inadvertently, by a seller, and returned as soon as noticed. Although this is a

minor cash difference, if it had not been returned by the seller, it could have been assumed as

part of the cash over/short difference, which identifies a need for stronger cash management

controls.

Section 10 of the Standard Procedures for Ticket Raffles states, in part, that “If your organization has

a gaming bank account, all cash or cash equivalent proceeds from the ticket raffle must be deposited

into the gaming account as soon as possible following receipt of those funds”

Recommendations for Compliance Enhancement

Based on our findings, we recommend that the organization implement the following corrective actions:

1. Ensure that there are procedures in place to verify the ticket reconciliation and that all tickets sold are

in the barrel, previous to conducting the draw.

2. Ensure that the organization notifies the Gaming Policy and Enforcement Branch immediately of any

activity or incident that may affect the integrity of the draw.

3. Ensure the database information is reliable to enable accurate verification of winning tickets.

4. Ensure that all valid tickets gets printed to the barrel, specifically, tickets jammed in the process of

printing. Ensure that there are procedures in place to verify that all tickets jammed were reprinted and

that the verification process gets documented and maintained as part of the gaming records.

5. Ensure that void tickets are consistently and accurately reported.

6. Ensure that a Ticket Reconciliation report is generated previous to each draw and maintained as part

of the gaming records.

7. Ensure that there is consistency in the units used in the reports and that the information is segregated

enough to allow manual check of the totals, specifically, data related to tickets sold and void tickets.

Ensure that the information in the summary reports is consistent, accurate, and traceable to individual

ticket numbers.

8. Should data be recreated or revised for a particular event, ensure that corrective entries and notes are

entered into the system in a timely manner. Archiving data not meant for reporting, with appropriate

notes and read only access to the users, can be an option as well.

9. Procedures should be in place to ensure that mobile ticket reprints are issued only if a printer error

occurs. Ensure that procedures are in place for a regular and documented follow up of mobile ticket









reprints reports per seller.

10. Ensure that only the sales that make part of the Ticket Reconciliation are reported as sales. Any other

type of revenue generated should be clearly disclosed and reported separately to provide clear audit

trail to the raffle revenue.

11. Ensure that cash proceeds from ticket raffle are deposited as soon as practical after the draw. Ensure

that cash control procedures are in place to trace cash differences that may be originated in voluntary

or involuntary errors.

Organization’s Comments

The organization responded with a letter dated February 15, 2013. In the letter the organization addressed

most of the issues and each one of the recommendations to indicate action in place, or to be implemented. A

copy of the letter is attached.



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Appendix B: Event Inspection - Canucks for Kids Fund

(January 19, 2013)


This report is the property of the Audit and Compliance Division of Gaming Policy and Enforcement Branch and is not

intended for use or circulation beyond specified recipients without the permission of the Director of Audit and

Compliance, Gaming Policy and Enforcement Branch. The audit is limited to the evaluation of compliance with Branch

policies and procedures and the findings express no opinion on the financial statements. The findings in our final report

may set forth instances of non-compliance with the Gaming Control Act, Regulation, and/or other Branch policy

documents. While instances of non-compliance may jeopardize ongoing eligibility for gaming access, eligibility is

determined solely by the Licensing and Grants Division, which will receive a copy of this report.




GAMING EVENT REVIEW

Date: March 25, 2013



Licensee: Canucks for Kids Fund

Org #: 103204 Char #: 7293 Date of Review: January 19, 2013

Type of Review: Event Inspection License #: 46728

Type of Gaming Access: Licensed Gaming Event (Class A-50/50 Ticket Raffles)

Sector: Human and Social Services

Audit Findings

For the date reviewed, we identified the following instances of non-compliance:

1. Further to our Report of Compliance Audit Findings, Char 7029, for the licensed period Sep. 1/11

to Jun. 30/12, the following issues were noted on the January 19th

event inspection:

Voided tickets reporting issues;

Sellers tickets reprint issue.

For details of these issues and of the organization’s compliance enhancement response, please

refer to Char 7029, which had not been sent to the organization at the time of the January 19th

event inspection.

2. In addition to the issues of void tickets noted in Char 7029, the licensee does not have the ability

to generate a system report that lists all void tickets numbers, to provide for a clear audit trail to

the physical void tickets. As the void tickets have a counterfoil in the barrel, sufficient and

adequate audit trail from the physical void tickets to the void tickets numbers in the system is

required to verify that only eligible tickets form part of the draw.

Gross Sales $

Total Cost of Prizes - Note 1 $

Donated Prizes

Total Net of Prizes 77,195.00$

Note 1: The total prize paid at the event was $146,838 including unclaimed prizes carried forward of $31,720 from

January 4, 2012 and $37,923 from March 1, 2012.









Section 9.1 of the Standard Procedures for Ticket Raffles, states, in part, that “Your organization

must be able to account for all tickets, whether sold or unsold.

3. Some ticket sellers pre-printed tickets from their handheld units to expedite sales. Since unsold

printed tickets must be voided prior to the draw, the potential number of tickets that have to be

voided after being pre-printed into the barrel is therefore increased. Issues have been noted

regarding void tickets, both in Char 7029 and in the current report, bullet # 2 above.

4. Sellers handed over the sales cash proceeds on a table located in the concourse, right to the direct

view of the passing public. Although there were three security guards around the table, unloading

significant amount of cash on the direct view of the public may be a security concern.

5. The person responsible for drawing the winning ticket did not have a bare arm, from the elbow to

the hand, when reaching into the barrel. 12.1 of the Standard Procedures for Ticket Raffles states,

in part, “Where the method of selecting the winner is by drawing a counterfoil from a barrel or

some other form of container, the following requirements must be met: The person responsible for

selecting winning counterfoils must not wear jewellery or clothing on the arm reaching into the

container; the arm must be bare from the elbow to the hand.”

6. The organization used an image of minors in its advertising of its licensed events; specifically, on

the current licence 50/50’s webpage. Section 6 of the Standard Procedures for Ticket Raffles

states, in part, that “When organizational materials include images of minors on pages where

gaming is referred to, the materials:

o Must adhere to the Advertising and Marketing standards issued by the Province;

o Must be approved in writing in advance by the Gaming Policy and Enforcement

Branch;

o Must not include any reference to marketing, sale or purchase of any lottery or gaming

products.

o May include images of beneficiaries in an appropriate and relevant setting. In general,

images should be of large groups. Images of individual minors will be acceptable only if

it can be demonstrated that no large-group images are possible and appropriate;

o May include the licensee’s brand and/or logo and refer to the beneficiaries; and

o May appear on website pages operated by the licensee or a partner organization

providing the pages contain material related only to beneficiaries of the licensee’s

programs and no material promoting sale or purchase of any gaming products. Website

pages operated by any organization with which the licensee has a relationship (e.g.: a

partner organization) or any of that organization’s communication materials (e.g.:

newsletters), may not use images of minors in relationship to, or in the vicinity of,

gaming products or related materials.”

The organization was advised about the advertising issue as soon as it was noted. The

image was removed within one day.










Based on our findings, we recommend that the organization implement the following corrective actions:

1. Refer to recommendations and organization’s response to audit report, Char 7029.

2. Ensure that there are procedures in place to verify and document that all void tickets on the system

correspond to the exact physical inventory of void tickets. The ability of the licensee to generate a

system report of void tickets numbers is an option.

3. Ensure that sellers are instructed not to pre-print tickets, thereby minimizing the number of void

stubs in the barrel.

4. Ensure that the location for the sellers handing over of cash proceeds is not in direct view of the

passing public.

5. Ensure that the person responsible for selecting the winning counterfoil has their arm reaching

into the barrel bare from the elbow to the hand.

6. Ensure that images of minors are not used in any page where the gaming event is referred to.

Organization’s Comments

The organization responded with a letter received via email on March 22, 2013. In the correspondence

the organization addressed each of the issues and indicated action in place and/or to be implemented. A

copy of the letter is attached.



August 15, 2013 of 51

Appendix C: Event Inspection - BC Lions Football Club

(October 29, 2012)












GAMING EVENT REVIEW

Date: January 16, 2013



Licensee: BC Lions Football Club - CFG

Org #: 117946 Char #: 7171 Date of Review: Oct. 19, 2012

Type of Review: Registered Raffle Event Inspection License #: 45150

Type of Gaming Access: Class A Gaming Event Licence

Sector: Sport

Scope: Observation of the event procedures including ticket draw. The review did not encompass testing of

system controls or functionality of ticket systems.

On October 19, 2012, four representatives from the Gaming Policy and Enforcement Branch attended

the BC Lions game to observe the electronic 50/50 system in operation and to perform a ticket

inspection including securing ticket stubs for analysis. There were twenty seven paid ticket sellers,

each of whom were connecting to the system using a handheld device and printer with which to sell

tickets in their assigned areas of the stadium or who were assigned to work at a stationary kiosk.

Several representatives of the licensee were present, as well as volunteers from the BC Football

Conference.

Observations

a. Prior to the start of the event, the handheld units could not be connected to the network and had

a different IP address from the server. This issue was resolved with the help of the 50/50

Central Help Desk and a manual reset of each handheld device before they were issued to the

sellers.

b. One of the stationary units could not be activated and was replaced with a spare unit

.

c. During ticket sales, there were many problems in synchronizing the handhelds (i.e. transferring

the sold ticket information to the system and reloading with more ticket numbers to sell).

Gross Sales $

Total Cost of Prizes $

Donated Prizes $

Total Net of Prizes 33,942.50$









d. As ticket sales continued, an increasing number of sellers in the stadium were unable to

synchronize their units and the volunteer overseeing the printers spent most of the event

running around the stadium from one seller to the next to assist.

e. At the close of sales, when the sellers returned to hand in cash and equipment, it appeared that

several sellers were having trouble completing the final synchronisation. There was no response

given to the auditors’ questions as to the reason for this. On reconciling, some sellers reported

fairly large cash overages which could not be explained at that point in time.

f. While the draw process was ongoing the printer volunteer began unplugging the printers. In the

process, he accidentally unplugged the main server prior to the winning ticket being validated.

However, the system was rebooted in time to allow for validation.

Audit Findings

Several issues were observed at the event:

1. In the weeks following the October 19th

event, the Audit and Compliance Division conducted a

ticket count and verification of the 48,406 tickets, in which we identified the following issues.

1 printed ticket had 2 numbers but only 1 barcode.

The 2nd number on the ticket was also printed on a separate ticket which also included

a barcode.

2 tickets that appeared to have the same number as a result of printer malfunction (the

barcodes, which are much smaller, were different).

Several tickets which were cut much smaller than the norm.

Several tickets that were badly “scrunched up”, which appeared to be the result of

printing issues and needed to be smoothed out for the counting procedure.

2 tickets listed as printed and sold which were not found.

Section 12 of the Standard Procedures for Ticket Raffles states, in part, “Each ticket purchased

by a draw cut-off date must have the same chance to win in that draw.”

2. Tickets were issued from the printers which fell to the floor after the ticket barrel was removed

and en route to the stadium for the draw. They were collected and put into the barrel before the

draw. No explanation has been provided to date for the precipitate removal of the barrel.

Section 12.1 of the Standard Procedures for Ticket Raffles states, in part, “Before conducting

the draw, your organization must: ensure each sold ticket forms part of the draw.”









3. There was inadequate supervision of the printers during the event. The printer volunteer was

not in the “control room” for much of the event as he was troubleshooting for ticket sellers who

experienced increasing difficulty in synchronizing their units. The other volunteer in charge of

the server computer often had two phones to his ears, while also attempting to implement on

the server the suggestions of the 50/50 Central Help Desk to rectify the synchronization issue.

At one such point while the server volunteer was occupied, three of the printers were not

operating because they required paper.

Section 2.2 of the Standard Procedures for Ticket Raffles states, in part, “The volunteer Board

members of your organization are responsible for the proper conduct and management of

gaming events for which they are licensed,” which includes ensuring that the equipment used at

the gaming event is in good working order.

4. It appeared that some ticket sellers were permitted to pre-print tickets from their handheld units

to expedite sales. Since unsold printed tickets must be voided prior to the draw, the potential

number of tickets that have to be voided after being printed into the barrel is therefore

increased. Since the ticket “stubs” are already in the barrel, the winning ticket drawn must be

validated in the system prior to announcement of the winner in case it turns out to be a void

number.

Section 12.1 of the Standard Procedures for Ticket Raffles states, in part, “Before conducting

the draw, your organization must: ensure each sold ticket forms part of the draw; and reconcile

the number of sold tickets and unsold tickets with the number of counterfoils in the draw

container, to ensure that only eligible tickets form part of the draw.”

5. After the event was over, when the tickets were being transferred from the barrel to the plastic

bag(s) by the organization, several from each handful fell to the floor and were picked up. It is

not known if any were missed.

Section 9.1 of the Standard Procedures for Ticket Raffles states, in part, “All ticket stubs or

counterfoils, and unsold tickets, must be retained for two years or until the Branch has audited

that particular raffle, whichever comes first.” While this section does not normally apply to

bearer tickets, the licensee had been advised to retain all tickets until further notice, given the

change in processes arising from the electronic ticketing system.

6. There was no Responsible Gambling messaging on the Jumbotron or point of sale screens.

Gaming Policy and Enforcement Branch advertising and marketing standards, specifically

Section 7 of the Conditions for a Class A and Class B Gaming Event Licence state, “The

licensee must comply with the advertising and marketing standards as specified in the

applicable Standard Procedures.” Section 5 of the Standard Procedures for Ticket Raffles

details the requirements pertaining to raffles.










Based on our findings, we recommend that the organization implement the following corrective

actions:

1. The organization should ensure that procedures are in place to ensure that all tickets are printed

into the barrel, each ticket printed is uniform in size and each number is only represented once.

We specifically recommend constant supervision of printers and very careful paper refills when

there are a large number of tickets being printed to avoid misprinted or malformed tickets.

2. Ensure that all ticket stubs have been printed prior to disconnecting and moving the barrel.

3. Ensure that sufficient volunteers are on site to handle eventual issues. It is suggested that a

minimum of 3 persons are required: 1 to operate the server, 1 to oversee the printers and 1 to

act as a runner or spare, should it be required.

4. Ensure that sellers are instructed not to pre-print tickets, thereby minimizing the number of void

stubs in the barrel.

5. Ensure that when the barrel is emptied and tickets removed to the storage bags, due care and

attention is paid to not losing any. The surrounding area should be carefully examined when

the barrel is empty to ensure that any stray tickets are collected.

6. Ensure that any advertising media, including the Jumbotron or other screens, include the

Responsible Gambling messaging..

Organization Comments

The licensee responded to the draft report with a letter dated January 11, 2013. In the correspondence,

the licensee addressed each of the issues and provided clarification that resulted in the removal of audit

finding #4. As a result of the removal, the subsequent findings were re-numbered. A copy of the letter

is attached.



August 15, 2013 of 51

Appendix D: Letter - Canucks for Kids

Q BRITISH

COLUMBIA

November 13, 2012

Mr. TC Carling Vice President - Communications and

Community Partnerships Canucks Sports & Entertainment [email protected]

Dear Mr. Carling:

Know your limit, play within it.

Log #486370

This letter is intended as an update regarding the use of electronic 50/50 systems for charitable fundraising in British Columbia. As you are aware, because of the difficulties experienced by all charities using this relatively new technology, the Oaming Policy and Enforcement Branch (OPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (OLI), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and OLI.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, OPEB will start the process of determining its use by charities in conjunction with a proper operating environment. This will not be immediate, however, because the issues identified with the use of the technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.

Additionally, the charities using the technology will have new licensing conditions, which will be specifically developed for this technological tool. Charities will need to meet these conditions before they will be permitted to use the electronic systems, and once they meet those conditions, they may begin using the technology to conduct their 50/50 raffles. Special attention will need to be paid to the conditions of these licenses, which \\ill address the challenges which have arisen to date.

Please note that the manual system using paper tickets can continue in the interim. Charities are still able to conduct draws using the coils oftickets that they have used in the past, and are still able to raise funds. The suspension refers only to the electronic technology, not the draws themselves.

Ministry of Energy, Mines and Natural Gas

Gaming Policy and Enforcement Branch Assistant Deputy Minister's Office

Mailing Address: PO BOX 9311 STN PRQV GOVT VICTORIA Be vaw 9N1 Telephone: (250) 387-1301 Facsimile: (250) 387-1818

. . .12

Location: Third Floor, 910 Government Street Victoria, Be

Web: www.pssg.gov.bc.ca/gaming

I understand the challenges that suspending the use of the technology raises for both companies and charities, and look forward to their resolution. Please do not hesitate to contact us if you have any questions or concerns.

Sincerely,

Douglas S. Scott Assistant Deputy Minister



August 15, 2013 of 51

Appendix E: Letter - BC Lions

Q BRITISH

COLUMBIA

November 13, 2012

Jamie Taras BC Lions Football Club Inc. 10605 City Pathersy Surrey BC [email protected]

Dear Jamie Taras:


Log #486370

This letter is intended as an update regarding the use of electronic 50/50 systems for charitable fundraising in British Columbia. As you are aware, because of the difficulties experienced by all charities using this relatively new technology, the Gaming Policy and Enforcement Branch (GPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (GLI), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and GLI.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, GPEB will start the process of determining its use by charities in co'1iunction with a proper operating environment. This will not be immediate, however, because the issues identified with the use ofthe technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.

Additionally, the charities using the technology will have new licensing conditions, which will be specifically developed for this technological tool. Charities will need to meet these conditions before they will be permitted to use the electronic systems, and once they meet those conditions, they may begin using the technology to conduct their 50/50 raffles. Special attention will need to be paid to the conditions of these licenses, which will address the challenges which have arisen to date.

Please note that the manual system using paper tickets can continue in the interim. Charities are still able to conduct draws using the coils of tickets that they have used in the past, and are still able to raise funds. The suspension refers only to the electronic technology, not the draws themselves.


Gaming Policy and Enforcement Branch Assistant Deputy Minister's Office

Mailing Address: PO BOX 9311 STN PROV GOVT VICTORJA Be vaw 9N1 Telephone: (250) 387~1301 Facsimile: (250) 387-1818

...12




Sincerely,




August 15, 2013 of 51

Appendix F: Letter - Kamloops Blazers

Q BRITISH

COLUMBIA

November 13,2012

Ms. Sheri Allen Kamloops Blazers Scholarship and

Education Society 1523 Robinson Crescent Kamloops BC V2C 332 [email protected]

Dear Ms. Allen:


Log #486370

This letter is intended as an update regarding the use of electronic 50/50 systems for charitable fundraising in British Columbia. As you are aware, because of the difficulties experienced by all charities using this relatively new technology, the Gaming Policy and Enforcement Branch (GPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (GLI), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and GLI.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, GPEB will start the process of determining its use by charities in conjunction with a proper operating environment. This will not be immediate, however, because the issues identified with the use of the technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.





Assistant Deputy Minister's Office

Mailing Address: PO BOX 9311 STN PROV GOVT VICTORIA Be vaw 9N1 Telephone: (250) 387-1301 Facsimile: (250) 387-1818

...12

Location: Third Floor, 910 Govemment Street Victoria, Be


I understand the challenges that suspending the use of the technology raises for both companies and charities, and look forward to their resolution, Please do not hesitate to contact us if you have any questions or concerns,

Sincerely,




August 15, 2013 of 51

Appendix G: Letter - Curl BC

..... <gEW& ... ~. A-;;;;;;"_'-':"'_~

W BRITISH

COLUMBIA

November 13, 2012

Mr. Scott Braley Curl BC 293 - 3820 Cessna Drive Richmond BC V7B OA2 [email protected]

Dear Mr. Braley:


Log #486370

This letter is intended as an update regarding the use of electronic 50150 systems for charitable fundraising in British Columbia. As you are aware, because of the difficulties experienced by all charities using this relatively new technology, the Gaming Policy and Enforcement Branch (GPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (GU), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and GU.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, GPEB will start the process of determining its use by charities in conjunction with a proper operating environment. This will not be immediate, however, because the issues identified with the use of the technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.

Additionally, the charities using the technology will have new licensing conditions, which will be specifically developed for this technological tool. Charities will need to meet these conditions before they will be permitted to use the electronic systems, and once they meet those conditi<;lns, they may begin using the technology to conduct their 50/50 raffles. Special attention will need to be paid to the conditions of these licenses, which will address the challenges which have arisen to date.





Mailing Address: PO BOX 9311 STN PROV GOVT VICTORIA BC V8W 9N1 Telephone: (250) 387-1301 Facsimile: (250) 387·1818

...12

Location: Third Floor, 910 GovemmentStreet Victoria, BC

Web: www.pssg.gov.bc.caJgaming


Sincerely,




August 15, 2013 of 51

Appendix H: Letter - Rycom

November 13,2012

Mr. Casey J. Witkowicz President and CEO RYCOM Management Corporation 6201 HWY, Unit 8 Vaughan ON L4H OK7 [email protected]

Dear Mr. Witkowicz:


Log #486370

This letter is intended as an update regarding the use of electronic 50150 systems for charitable fundraising in British Columbia. As you are aware, because of the difficulties experienced by all charities using this relatively new technology, the Oaming Policy and Enforcement Branch (OPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (OLI), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and OLI.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, OPEB will start the process of determining its use by charities in conjunction with a proper operating environment. This will not be immediate, however, because the issues identified with the use of the technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.

Additionally, the charities using the technology will have new licensing conditions, which will be specifically developed for this technological tool. Charities will need to meet these conditions before they will be permitted to use the electronic systems, and once they meet those conditions, they may begin using the technology to conduct their 50150 raffles. Special attention will need to be paid to the conditions of these licenses, which will address the challenges which have arisen to date.





Mailing Address: PO BOX 9311 STN PROV GOvr VICTORIA Be V8W 9N1 Telephone: (250) 387-1301 Facsimile: (250) 387-1818

. . .12


Web: WWW.PSS9·Qov.bc.ca/gaming


Sincerely,




August 15, 2013 of 51

Appendix I: Letter - Pointstreak

-...it!i .. };;.:>~

Q BRITISH

COLUMBIA

November 13, 2012

Mr. Scott Secord President and CEO Pointstreak 50 Minthorn Blvd, Suite 400 Thornhill ON L3T 7X8 [email protected]

Dear Mr. Secord:


Log #486370

This letter is intended as an update regarding the use of electronic 50/50 systems for charitable fundraising in British Columbia. As you are aware, because ofthe difficulties experienced by all charities using this relatively new technology, the Gaming Policy and Enforcement Branch (GPEB) has suspended its use at present. Some of the technological equipment has already undergone the initial technical audit by an independent test laboratory (GU), and more equipment is about to do so. The audit is paid for by the companies in question, and is handled through a contract between the company and GU.

Please note that until the systems can be operated without error, the technology cannot be approved for use. If the technology passes the testing, GPEB will start the process of determining its use by charities in co~unction with a proper operating environment. This will not be immediate, however, because the issues identified with the use of the technology were not solely technical. There were concerns related to the facilities in which the charities are operating, and also with operator training. These issues will have to be sorted out before charities can resume the use of the technology to conduct their fundraising.






Mailing Address: PO BOX 9311 STN PROV GOVT VICTORIA BC V8W 9N1 Telephone: (2S0) 387-1301 Facsimile: (2S0) 387·1818

...12

Location: Third Floor. 910 Government Street Victoria, BC



Sincerely,




August 15, 2013 of 51

Appendix J: Letter from Doug Scott, GPEB General Manager and

Assistant Deputy Minister (January 10, 2013)



Gaming Policy and Enforcement Branch Assistant Deputy Minister’s Office

Mailing Address: PO BOX 9311 STN PROV GOVT VICTORIA BC V8W 9N1 Telephone: (250) 387-1301 Facsimile: (250) 387-1818

Location: Third Floor, 910 Government Street Victoria, BC Web: www.pssg.gov.bc.ca/gaming

January 10, 2013 Log # 488154 Mr. Paolo Aquilini President Standard Building, Main Level 510 West Hastings Street Vancouver BC V6B 1L8 E-Mail: [email protected] Dear Mr. Aquilini: I am writing in response to a failure of the Canucks for Kids Foundation’s (CFKF’s) electronic 50/50 system on April 21, 2012, which resulted in approximately 43,000 eligible tickets not being entered into that draw.

The failure of CFKF to notify the Gaming Policy and Enforcement Branch (GPEB) of the event until a pre-audit meeting of this electronic 50/50 system on August 3, 2012 greatly compounded the problem and limited the options available for response.

I appreciate the subsequent efforts of the CFKF board and staff to address the issue and assist GPEB with the technical evaluation of the system. However, the original delay in reporting was in direct contravention of the terms and conditions of your gaming licence, which requires system failures that impact the integrity of the game to be reported immediately to GPEB. Reporting without delay is mandatory under section 2.2 of the Guidelines: Applying for a Class A or Class B Event Licence:

Section 86(2) of the Gaming Control Act (GCA) requires all licensees to notify GPEB’s Investigations and Regional Operations division without delay regarding any conduct, activity or incident that may be considered contrary to the Criminal Code of Canada, the Gaming Control Act or Gaming Control Regulations, or that may affect the integrity of gaming. Failure to meet these requirements may result in suspension or revocation of a gaming event licence, refusal of future gaming event licences and/or denial of future access to gaming grants or funds.

Therefore, as a result of failure to report the malfunction, as required by the Gaming Control Act, I hereby issue the Canucks for Kids Foundation a formal warning. If such a circumstance should arise in the future, and CFKF fails to report it immediately, the Foundation will forfeit its licence to operate a 50/50 raffle.

.../2

Considering options available regarding the people who purchased a ticket on April 21, I recognize that the cash-based nature of the 50/50 makes identification of players virtually impossible, and a direct remedy is likely impractical. However, as discussed with individual members of your board, GPEB determined that there is a duty to inform the public prior to conducting the next 50/50 draw. It is important to ensure that people considering the purchase of a ticket are fully informed of what occurred during a previous draw. I understand your board has also come to this same conclusion.

Consequently, by way of this letter, I confirm the requirement that Canucks for Kids Foundation make a public announcement in advance of conducting the next 50/50 draw on January 19, 2013. As agreed, this announcement will take the form of an open letter posted on the Vancouver Canucks website on Thursday, January 10, 2013. The letter will also be electronically mailed out to Canucks newsletter subscribers on January 16, 2013.

To address technical aspects of the failure, GPEB suspended the use of Bump 50/50 technology until an independent test lab was able to review and evaluate the technology. Since the technology has now passed certification, a new licence permitting use of the technology will be issued to CFKF. There will be new conditions related to the use of this technology; moreover, it is possible that additional conditions will be developed after the licence has been issued. Please note that the Foundation will have to abide by all of these conditions to maintain its licence.

While I have very serious concerns regarding what transpired as a result of the April 21 system failure, I know this incident is also of great concern to your charitable organization. Our records show your organization’s past compliance as a charitable gaming licensee has been exemplary, and as previously noted, I appreciate the significant efforts CFKF has made this fall.

If you have any questions or concerns, please feel free to contact me directly, or Kathy Elder, Director of Licensing, at (250) 356-6479.

Sincerely,




August 15, 2013 of 51

Appendix K: Canucks for Kids Fund Open Letter

CANUCIS

iDS l!Iall

800 GRi ff iTHS WAY VANCOUVER. Be CANAOA. V6B 6GI

canucks .com

CANUCKS FOR KIDS FUND OPEN LEITER

The Canucks for Kids Fund (CFKF) has been in the service of children and families in British Columbia for the past 27 years, granting over $40 million. With the incredible passion and generosity of our community, we have helped build Canucks Autism Network, Canuck Place Children's Hospice, the Canucks Family Education Centre and the Canucks Centre for BC Hockey.

Entering the 2011.12 season, the Canucks for Kids Fund made a significant investment to enhance the 50/50 program by moving from paper tickets to an electronic system, with the goal to increase fundraising and enhance the in-game experience.

During the Canucks last home game of the season on April 22, 2012, we experienced an unexpected system failure that resulted in not all 50/50 transactions being processed before the draw was conducted . At the time of the failure, we were advised by our technology partners that the data was lost and could not be recovered. After giving serious consideration to all alternatives, we made the decision to conduct the draw despite the malfunction and awarded the winner the sum of $51,465, with the equivalent sum of $51,465 donated to CFKF.

Following the event night, we worked with our technology partners and it was determined that data initially believed to be lost from the event transactions could in fact be retrieved. As a result, we discovered that approximately 43,000 of the 80,000 tickets were not processed in time for the draw.

Throughout the off season, the electronic system has been thoroughly tested by an independent third party who has determined that the system is ready to operate at the next Canucks home game. The ministry's Gaming Policy and Enforcement Branch that regulates all gaming in British Columbia have approved continued use of the system. Nevertheless, in the unlikely event a future draw is compromised by further technical issues, we have put in place several additional procedures to protect the integrity of all 50/50 program ticket purchases.

The Canucks for Kids Fund regrets the system malfunction and the impact it had on some of the patrons at the April 22 game. If you have any further questions or concerns regarding the 50/50 program or CFKF, please let us know at ([email protected]) and we will work diligently to answer them as quickly as possible.

Canucks for Kids Fund Board of Directors



August 15, 2013 of 51

Appendix L: Certificate of Technical Integrity - Bump 50:50

ISSUE DATE: January 11, 2013 CERTIFICATE NO: C-4300

CERTIFICATE OF TECHNICAL INTEGRITY

STATUS: CERTIFIED The Gaming Equipment and/or Supplies described in this certificate are certified and approved pursuant to the BC Gaming Control Act for use within the Province of British Columbia, subject to any restrictions and/or conditions contained herein. NAME: BUMP 50:50 MANUFACTURER: BUMP WORLDWIDE INC CATEGORY: Software and Hardware TYPE: Electronic Raffle System COMPONENT ITEM #1: Part/ID No: /var/www/html/ Version/ Date Code: 1.5.1.3 BD Function: Electronic Raffle System Description: Linux Game Server Signature Type: MD5 Signature: BD659ACD2524D689A301C1AF5DF446E9 COMPONENT ITEM #2: Part/ID No: Vanbump15.apk Version/ Date 1.5.1.3 BD Function: Electronic Raffle System Description: Pod APK Installer Signature Type: MD5 Signature: F4FD026BFEF99BB0B852F1C176DF2102

RESTRICTIONS AND/OR CONDITIONS:

• The above listed gaming equipment/supplies are to be used in conjunction with compatible and GPEB approved programs and/or hardware as described in the below noted GLI reports, or compatible and GPEB approved upgrades.

o GLI Report: SY-63-BUM-12-01 dated November 9, 2012, and o GLI Report: SY-63-BUM-12-02 dated December 21, 2012.

• Any abnormalities that impact technical integrity are to be reported immediately to the Director, Certification and Game Integrity, GPEB.

• This certification document is specific to the version(s) tested as noted above. Any changes to software, ie version upgrades, bug fixes, etc must be reported to the Director, Certification and Game Integrity, GPEB. All changes will be assessed on a case by case basis for continued certification.

Steve Lefler, Director/Deputy Registrar Certification and Game Integrity


Registration and Certification Division

Mailing Address: PO BOX 9202, STN PROV GOVT VICTORIA BC V8W 9J1 Telephone: (250) 356-0663 Facsimile: (250) 356-0782

Location: Third Floor, 910 Government Street Victoria, BC V8W 9J1




August 15, 2013 of 50

Appendix M: BC Lions Football Club

Raffle Licence - Percentage Draw

Ministry ofPublic Safety andSolicitor General

Gaming Policy and Enforcement BranchAssistant Deputy Minister's Office

Mailing Address:PO BOX 9311 STN PROV GOVTVICTORIA BC V8W 9N1Telephone:(250) 387-5311Facsimile:(250) 356-8149

Location:Third Floor,910 Government StreetVictoria, BC V8W 1X3Web: http://www.gaming.gov.bc.ca/


Gaming Event Licence

Gaming Event: Class A - Raffle Licence - Percentage Draw, Licence # 55553

Licence Period: 21-Jun-2013 - 17-Nov-2013

Issue Date: 02-Jul-2013

L+G File No: 117946

The Gaming Policy and Enforcement Branch has approved and issued a Class A Raffle Licence -

Percentage Draw for the purposes outlined in application number 1009004 to:

BC Lions Football Club Inc. - CFG

10605 City Park Way

Surrey BC

V3T 4C8

Event Contact: Jamie Taras, 604-930-5467

The Licensee must comply with the Criminal Code of Canada, British Columbia's GamingControl Act and Regulation, all other applicable federal, provincial and municipal laws, andrelevant conditions, standard procedures, policies, procedures and orders issued by the GamingPolicy and Enforcement Branch. Gaming events must be conducted at the location on the dates and the times specified on thislicence. Any changes must be approved in writing prior to the start of the event. If you do not agree with this decision, please refer to our internal review procedures at:http://www.gaming.gov.bc.ca/.

Ticket sales: 21-Jun-2013 - 17-Nov-2013

Total value of all prizes: 50% of total sales

Ticket price(s): 120000 tickets, 3 for $5.00; 280000 tickets, 7 for $10.00;

Ministry ofPublic Safety andSolicitor General

Gaming Policy and Enforcement BranchAssistant Deputy Minister's Office

Mailing Address:PO BOX 9311 STN PROV GOVTVICTORIA BC V8W 9N1Telephone:(250) 387-5311Facsimile:(250) 356-8149

Location:Third Floor,910 Government StreetVictoria, BC V8W 1X3Web: http://www.gaming.gov.bc.ca/


•

•

•

•

This licence is subject to the following conditions:

Reporting - Report is Due: It is mandatory that you complete the Gaming Event Revenue

Report within 90 days after your event has occurred and your license period expires. This

form can be located on our website at http://www.gaming.gov.bc.ca/licences/docs/form-

event-revenue-rpt.pdf? These reports can be submitted by regular mail, facsimile: 250-356-

8149 or by email to [email protected].

Admin Required: Section 86(2) of the Gaming Control Act (GCA) requires all licensees to

notify GPEB's Investigations and Regional Operations division without delay regarding any

conduct, activity or incident that may be considered contrary to the Criminal Code of

Canada, the Gaming Control Act or Gaming Control Regulations, or that may affect the

integrity of gaming

Admin Required - Intended Use of Licence Event Proceeds: The use of net gaming proceeds

is approved for dispursement to eligible amateur football organizations. The funds are used

to help develop and grow amateur football in BC.

July 2/13 amendment: corrected number of tickets for sale

300000 tickets, 15 for $20.00

Draw date(s) and/or location:

Draw dates as per BC Lions Scheduled games late in 3rd quarter or beginning of 4th

quarter at BC Place Stadium 777 Pacific Boulevard, Vancouver BC.,

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gaming enforcement action - electronic 50/50 … · gaming enforcement action – electronic 50/50...

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