Responsible Gaming Code of Practice Version 6.0

PHILIPPINE AMUSEMENT AND GAMING CORPORATION RESPONSIBLE GAMING CODE OF PRACTICE Version 6.0 2021 GAMING LICENSING AND DEVELOPMENT DEPARTMENT

RG Code of Practice Version 6.0 TABLE OF CONTENTS Foreword................................................................................................ 5 I. .. 6 II. .. ... 8 III. Limited . .. 9 IV. Financial Transactions 11 Anti-Money Laundering Act 11 Credit 11 Banking Access 11 V. Fair Gaming .. 12 VI. Awareness Program .. . 13 VII. Advertisements 15 15 15 15 C. 16 VIII. Facilities 17 Child Care 17 Entertainment Venues 17 IX. Training of ... 18 X. Support Facilities 19 Helpline 19 Feedback System 19 XI. Exclusion Program 21 Player Exclusion Types 21 1.a Self Exclusion 21 1.b Family Exclusion 22 1.c Licensee-emanating Exclusion 25 Submission of Application 26 27 2

RG Code of Practice Version 6.0 XII. Table of Penalties 28 XII. Help Centers in the . .. 29 3

RG Code of Practice Version 6.0 ANNEXES RG Form 01 Employee Verification Form RG Form 02 Self Exclusion Application Form RG Form 03 Family Exclusion Application Form RG Form 04 Licensee-emanating Exclusion Order RG Form 05 NDRP On-line User Access Control Form RG Form 06 Endorsement for Electronic Personal Disclosure Statement RG Form 07 Personal Disclosure Statement Online User Access Control RG Form 08 Petition to Amend the Exclusion Period RG Form 09 Player Exclusion Order RG Form 10 Notice to Show Cause RG Form 11 Notice of Imposition of Penalty RG Form 12 RG Compliance Report RG Form 13 Notice of Non-compliance Annex A National Database of Restricted Persons (NDRP) User Manual Annex B Personal Disclosure Statement Application Guide Annex C Certificate of Non-Filing of Annual Income Tax Return Diagram 1 Employee Verification Flowchart Diagram 2 How to Submit Personal Disclosure Statement Electronically Diagram 3 Compliance Verification Flowchart 4

RG Code of Practice Version 6.0 FOREWORD wagering, odds and prizes. While it is considered an enjoyable form of entertainment, gaming can have a negative impact on the player or his family and community when done in excess. PAGCOR, the Philippine government arm that regulates authorized gaming establishments around the country, expects gaming services provided by its Licensees to be delivered in a responsible manner. This Code of Practice sets out rules and guidelines on Responsible Gaming (RG) that will be adopted by all PAGCOR-operated and licensed entities in authorized gaming establishments, in order to minimize potential harm to the individual players and the community, to prevent gambling addiction and to prohibit underage gambling. Though the principles are intended to apply to all gaming operators, the method of implementing this Code will vary according to the form of gaming. The Rules defined herein are based on present best global practices. They must be complied with as minimum standards. Manuals for different forms of gaming shall have specific implementing guidelines. As best global practice is constantly evolving and changing in the light of updates in research, technology and business practices, this Code of Practice and the different Manuals will be subject to regular review and evaluation. 5

RG Code of Practice Version 6.0 I. DEFINITION OF TERMS Billboard - a panel for the display of advertisements in public places, such as alongside highways or on the sides of buildings.1 Financier/Loan Shark - a moneylender who charges extremely high rates of interest, typically under illegal conditions Source: (http://www.bing.com/search?q=definition+loan+shark&src=IETopResult&FORM=IETR0&conversationid+) Gaming - means playing games of chance in casinos and gambling establishments and any variations thereof, including but not limited to the games of chance referred to in the Provisional License or Gaming License, whichever is applicable. Gaming Employment License (GEL) - an authorization issued by PAGCOR granting a person the privilege to be employed as a gaming employee within the Philippine jurisdiction. Licensee - the entity to which a Provisional License or Gaming License was issued by PAGCOR as the case may be. National Database of Restricted Persons (NDRP) - a list of names with their personal information compiled and updated by PAGCOR who are prohibited from entering and from playing in specific PAGCOR-authorized gaming premises in the Philippines. Operator - a legal entity contracted by the Licensee to manage and conduct gaming activities in specific properties - may be PAGCOR or the Licensee itself 1 http://www.thefreedictionary.com/billboard 6

RG Code of Practice Version 6.0 Personal Disclosure Statement (PDS) - personal and financial information certified true by the members of the Board of directors of PAGCOR-authorized gaming entities PDS Database - a compilation of personal information as provided by the nominees of the Board of Directors of PAGCOR-licensees Problem Gambler - an individual affected by gambling to the point of no longer having normal control or rational judgment, leading to problems in other areas 2 Problem Gambling - an urge to continuously gamble despite harmful negative consequences or a desire to stop. It is often defined by whether harm is experienced by the gambler or others, rather than by the gambler's behavior.3 - a gambling behavior which causes disruptions in any major area of life: psychological, physical, social or vocational. The term "Problem Gambling" includes, but is not limited to, the condition known as "Pathological", or "Compulsive" Gambling, a progressive addiction characterized by increasing preoccupation with gambling, a need to bet more money more frequently, restlessness or irritability when attempting to stop, "chasing" losses, and loss of control manifested by continuation of the gambling behavior in spite of mounting, serious, negative consequences.4 2 http://www.data.amity.org.au 3 en.wikipedia.org/wiki/Problem_gambler 4 http://www.ncpgambling.org 7

RG Code of Practice Version 6.0 II. PROBITY MEASURES PAGCOR sets probity standards and measures to establish integrity, financial soundness, business ability and the suitability to serve in a By May 31 of each year, electronic submission of the Personal Disclosure Statement (PDS) must be accomplished by the members of the Board of Directors of licensed gaming venues as of December 31 of the previous year. Filipinos and resident foreigners must indicate their Tax Identification Number (TIN) and date of filing of their Income Tax Returns (ITRs) for the previous year. In case no income is earned from the previous year, a Certificate of Non-Filing of ITR must be accomplished. Non-resident foreign nominees of the Board must indicate their valid passport details (number, place of issuance and expiration date) in lieu of the ITR. ITRs, Certificates of Non-Filing of ITR and Passports must be kept on file as certified in RG Form 6. The PDS system recognizes the schedule of PDS electronic submission from January 1 to May 31 of every year. Any data entry after this period is considered late and may be subject to penalty as provided in the Regulatory Manuals. Refer to Annex B for the PDS Application Guide. 8

RG Code of Practice Version 6.0 III. LIMITED ACCESS 1. Pursuant to Presidential Decree 1869 (PAGCOR Charter) as amended by Republic Act 9487 and Malacañang Memorandum Circular No. 6 Series of 2016, the following persons are not allowed to enter, stay and/or play: a) Government officials connected directly with the operation of the Government or any of its agencies. b) Members of the Armed Forces of the Philippines, including the Army, Navy, Air Force or the Philippine National Police; and c) Persons under 21 years of age or student at any school, college, or university in the Philippines. 2. Persons included in the National Database of Restricted Persons 3. Registration of Gaming Members The Licensees are given sufficient leeway to formulate their own internal rules and policies relating to membership in their respective gaming establishments including, but not limited to registration of gaming members. 4. Employees of Licensees (GEL Holders) In order to maintain the integrity of the conduct of gaming, eliminate the possibility of problematic compulsive gambling among employees, avoid the possibility of heavily indebted employees due to gaming activities to engage in potential acts of dishonesty, theft, fraud and/or collusion of employees with players and/or other employees and prevent appearance of impropriety, all employees holding Gaming Employment License (GEL) are prohibited from playing in any gaming establishment in the Philippines. 9

RG Code of Practice Version 6.0 Should there be a need to verify if an employee violates such company policy, the procedure is shown in Annex B: Employee Verification Flowchart. RG Form 1 shall be accomplished. PAGCOR may impose, after compliance by licensees with due process requirements, the following penalties upon any employee found to be in violation of the aforesaid provision: First offense: six (6) months Second offense: Revocation of GEL 5. Financier/loan sharks and the like are prohibited from roaming in the casino/gaming premises and offering loans to players. [Source:CMED/-2017-06-0978] 10

RG Code of Practice Version 6.0 IV. FINANCIAL TRANSACTION 1. Anti-Money Laundering The legislative bodies of the government are taking measures to amend Republic Act No. 9160 or the Anti-Money Laundering Act of 2001 to include casinos as covered persons. 2. Credit No credit will be extended by the gaming operators to players without premium accounts and to non-VIP customers. 3. Commercial Banking Access All banking units located inside the gaming area should follow the prescribed transactions of Banko Sentral ng Pilipinas (BSP). Manned commercial banking facilities located inside the gaming area should be limited to foreign exchange transactions only. With regard to Automated Teller Machines, prudence should be exercised in determining their location. 11

RG Code of Practice Version 6.0 V. FAIR GAMING EXPERIENCE 1. Game rules must be defined, and game manuals must be approved by PAGCOR. 2. Gaming machines must be certified by international testing laboratories to ensure fairness. 12

RG Code of Practice Version 6.0 VI. AWARENESS PROGRAM 1. The Licensee must have efforts in creating awareness among its patrons about problem gambling. The following information should be provided: a) Definition of problem gambling b) Signs of problem gambling c) Age restrictions imposed by Philippine laws and regulations d) Negative impact of excessive gambling on the individual, family, and society e) Exclusion procedures and forms f) Helpline (mobile or landline) and email address and/or website g) Contact numbers of therapists, counselors and/or rehabilitation centers 2. Slogan A standard slogan must be visible in Responsible Gaming materials placed in gaming venues. 3. Communication Media Proposed layout must be presented to PAGCOR GLDD prior to publication. a) Signages as appropriate must be clearly visible and displayed in conspicuous locations such as: i. Access points ii. Toilets b) Official website - c) Betting and marketing materials, membership booklets, information leaflets and similar communication with RG information are made available to patrons. 13

RG Code of Practice Version 6.0 4. Standard RG Information a) Persons younger than 21 years old are not allowed to play. b) PAGCOR RG link www.pagcor.ph/regulatory and RG email address keepitfun@pagcor.ph 14

RG Code of Practice Version 6.0 VII. ADVERTISEMENTS 1. General Rule Advertising materials published in any form of media in the Philippines must be socially responsible. Said materials must not portray, encourage, or condone gambling behavior that is socially irresponsible or could lead to financial harm, directed at children or feature people who are or who appear to be under 21 years old, or suggest that gambling can be a solution to financial problems. 2. Mass Media Coverage a) Print b) Television and cable c) Radio d) Internet - Website - Blogs - Social media sites - Electronic mail e) Telephone marketing (SMS, MMS, calls) f) Promotional posters, tarpaulin streamers, fliers, and LED signage g) Billboards h) Mobile ads, vehicle wrap 3. Content a) Mandatory Elements 1) Prohibition of under 21 years old logo 2) RG slogan Keep it Fun 3) End tag for Radio ads: Keep it Fun. Game Responsibly. 4) Closing billboard/tag line for TV commercials, print ads, billboards, web-based promos and other media: Gaming for 21 years old and above only. Keep it Fun. Game Responsibly. 15

RG Code of Practice Version 6.0 b) Messages should not: 1) be directed to persons below 21 years old - must neither catch the attention nor give interest to the viewing minors 2) gambling activity - discourage the thought that skill and talent can change the result of the game or can assure a win 3) give the impression that gambling is an accepted way to make money - promote that gambling is more on entertainment, fun and leisure and not a money-making activity - must not imply that gambling solves financial problems 4) include misleading statements about odds and prizes - should not ensure winnings or prizes if not guaranteed 4. Location of Billboards be located not less than a 200-meter radius from schools and places of worship/churches, horse racing outlets, public markets, informal settlers, and resettlement areas. Please refer to the Gaming Site Regulatory Manuals for the definition of the stated locations. 16

RG Code of Practice Version 6.0 VIII. FACILITIES 1. Child Care Where gaming establishments do not have separate passageways from the gaming floor to and from food outlets and entertainment venues, minors (children less than 18 years old) must never linger, be left alone unaccompanied nor be unsupervised by their adult companions at all times. 2. Entertainment Venues The Licensee shall provide hospitality services and/or operate entertainment venues in or near the gaming area so as to encourage customers to take breaks in play. 3. Responsible Gaming helpdesk/kiosk in casinos The RG kiosk/helpdesk should be conspicuously located within the gaming area, should display RG slogan, must be manned 24/7 and is required to have the following at all times: RG representative, RG brochures/flyers/cards and exclusion application forms. 17

RG Code of Practice Version 6.0 IX. TRAINING AND MANAGEMENT OF STAFF The Licensee, in coordination with PAGCOR, are to conduct training programs, symposia, refresher courses and/or seminars on problem gambling for its employees. 1. These shall educate the employees on: - - How to spot a problem gambler - How to respond to questions about Responsible Gaming program - What to do when confronted by problem gamblers or relatives - Availability of helplines 2. Attendance at the seminars will be included as a requirement License (GEL). A webinar may be an alternative. 3. The Licensee will ensure that each employee is made aware of the referral details for problem gamblers or family members seeking help for their relatives with gambling problems, including the Exclusion Programs. 18

RG Code of Practice Version 6.0 X. SUPPORT FACILITIES Licensees are to establish gambling-related complaint resolution mechanisms to address gambling concerns, through helplines (landline or mobile) and internet (email or website). 1. Helpline a. Hotline - A 24/7 answer service may be made available to customers who seek help or to their immediate relatives. b. Official Network ID - promotional messages may be used to inform patrons of the availability of gambling-related complaint channels and of the status of their membership accounts. c. Email Account - An email address may be devoted to receiving problem gambling concerns. The Licensee is responsible for immediately replying to customers. Alternatively, a link to a website may be set up for easy access to responsible gaming programs such as requests for exclusion and referrals to therapists and rehabilitation centers. - Inquiries, requests for exclusion and application forms and other related concerns may be Gaming email address. d. Counseling Contact Information - Customers who feel the need for professional help or persons concerned about family member/s with gambling problem/s will be provided with contact information of appropriate counseling individuals or centers through passive channels. 19

RG Code of Practice Version 6.0 2. Feedback System Gaming providers must maintain a Responsible Gaming Incident Record to ensure that situations are acted upon and that corresponding actions taken by staff to assist people is according to rules. The following particulars should be put on record: a. Date, time, location, and nature of any event where a patron reports a gambling-related problem b. Name, address, and contact details (if known) or description of the person in relation to whom action was taken c. Action taken and by whom d. Name, address, and contact details of person requesting if not the problem patron himself e. Person or institution to whom patron was referred to 20

RG Code of Practice Version 6.0 XI. EXCLUSION PROGRAM Operators are to provide patrons who feel that relatives or they themselves are developing a problem with gambling with the option of barring them from playing in the gaming venues or sites. An Operator must not disclose information gathered during the facilitation of an application for Exclusion to any third party, unless All information and data, especially the identity of excluded persons, must be treated as classified information by the designated personnel of stakeholders of the Philippine gaming industry who are given access to the National Database of Restricted Persons or NDRP (see Annex D for User Guidelines). 1) Player Exclusion Types (a) Self Exclusion - Application can be initiated by sending an inquiry account. Exclusion forms may be downloaded through the PAGCOR website at www.pagcor.ph/regulatory and are available at PAGCOR operated and regulated gaming sites. - Applicant must submit the following documents: Photocopy of one (1) valid government ID card with photo and signature Fully accomplished RG Form 2 One (1) 2x2 photo taken within 6 months from application date - Applicant may request for an exclusion period of 6 months, 1 year or 5 years. After completion of the exclusion period, the self-exclusion order will be lifted automatically. A self-exclusion period for the first six (6) months is irrevocable. 21

RG Code of Practice Version 6.0 - Respondent for self-exclusion may apply for a Petition to Amend the Exclusion Period (RG Form 8) only after the 6-month irrevocable period. - Regardless of where application was applied, the self-exclusion order will be enforced in all PAGCOR operated and regulated gaming facilities. Names of excluded persons will be posted in the National Database of Restricted Persons. - Upon expiration, the Self Exclusion Order will be lifted automatically. The applicant may re-apply for exclusion (RG Form 2) by putting a check mark on the re-application box in the application form. GLDD RG Section shall verify all re-applications in the NDRP. (b) Family Exclusion - Exclusion forms may be downloaded through the PAGCOR website at www.pagcor.ph/regulatory and are available at PAGCOR operated and regulated gaming sites. - The family member is considered the applicant while the problem gambler is the respondent. - Any one of the following family members may Spouse child at least 18 years old parent - Immediate family member applying for exclusion must submit the following documents: 22

RG Code of Practice Version 6.0 If applicant is the parent: government ID with photo Certificate government ID with photo and signature One (1) 2x2 photo of respondent taken within 6 months from application date Fully accomplished RG Form 3 If applicant is the child: government ID with photo Certificate government ID or school ID with photo and signature One (1) 2x2 photo of respondent taken within 6 months from application date Fully accomplished RG Form 3 If applicant is the spouse: government ID with photo Photocopy of Marriage Contract government ID with photo and signature One (1) 2x2 photo of respondent taken within 6 months from application date Fully accomplished RG Form 3 23

RG Code of Practice Version 6.0 - In lieu of the Birth Certificate, a foreign applicant may submit an official document issued by its relationship, the authenticity of which must be certified by the Department of Foreign Affairs of the Philippines. Incomplete requirements will not be processed. - Applicant may request for an exclusion period of 6 months, 1 year and 3 years. After completion of the exclusion period, the family exclusion order will be lifted automatically. (See attached revised RG Form 3) - Upon expiration, the Family Exclusion Order will be lifted automatically. The applicant may re-apply for exclusion (RG Form 3) by putting a check mark on the re-application box in the application form. GLDD RG Section shall verify all re-applications in the NDRP. - Regardless of where application was applied, the Family Exclusion Order will take effect in all PAGCOR operated and regulated gaming facilities. Names of excluded persons will be posted in the National Database of Restricted Persons (NDRP). For reference of the operators, the NDRP Manual is attached as Annex A. 24

RG Code of Practice Version 6.0 (c) Licensee-emanating Exclusion - An Operator, on its own accord, may issue an exclusion order to bar a person from its gaming premises (RG Form4) on the following grounds: Cheating5 Theft6 Use of camera or any electronic device to assist in projecting the outcome of the game Possession of counterfeit chips, tokens, or cashless wagering instruments Unlawful interference with a gaming equipment Forgery or counterfeiting Money laundering Fraud Note: The Gaming Operator, however, may prohibit a person from entering its own gaming establishment under just reasons which are not included under the Licensee-emanating exclusion offenses, but said prohibition will not be observed in other gaming establishments. The prohibition of a person by a Gaming Operator in its own gaming establishment shall not be posted in the NDRP. - Committee of Assessors (CoA) Each Licensee will form its own CoA. The CoA for an exclusion order. 5 https://en.wikipedia.org/wiki/Cheating_in_casinos 6 http://philippinelaw.info/revised-penal-code/article-308_who-are-liable-for-theft.html 25

RG Code of Practice Version 6.0 - A Licensee may process an Exclusion Order to be effective in all gaming establishments by accomplishing the following which should be kept on file and readily available for audit by PAGCOR: Chief Operations Officer Complete Investigation Report proving that the respondent committed any of the grounds listed under XI.1.c (optional: with attached Police or Barangay Report) One recent photo of the respondent - PAGCOR will evaluate the recommendation based on the full Investigation Report, transcript of the interview with the respondent, and other pertinent documents. - A Licensee-emanating Exclusion Order can take effect for a period of 1 year, 5 years or lifetime. (see attached revised RG Form 4) - A Licensee-Emanating Exclusion Order will take effect irrevocably. While enforced, the nationwide exclusion order will be posted in the NDRP. - A person with Licensee-emanating Exclusion Order is not qualified to obtain a GEL. 2) Submission of Application Complete documentary requirements for Self and Family Exclusion applications, together with the fully accomplished and signed application form, must be submitted inside a sealed long-sized brown envelope addressed to: 26

RG Code of Practice Version 6.0 APPLICATION FOR EXCLUSION ORDER Gaming Licensing and Development Department PAGCOR Main Corporate Office 12th Floor, iMET BPO Tower CBP-1A Metropolitan Park Roxas Boulevard, Pasay City The envelope must be sent to the above address either through: a. personal delivery, or b. courier service located at the lobby of PAGCOR House. 3) Breach of Exclusion Order Once an Exclusion Order is given, it is the intention of this Code that such Order be not revoked before the expiration date. 27

RG Code of Practice Version 6.0 XII. TABLE OF PENALTIES Prohibited Persons Penalty a. Government officials connected directly with the operation of the Government or any of its agencies b. Members of the Armed Forces of the Philippines, including the Army, Navy, Air Force and the Philippine National Police Php100,000.00 per entry/play per c. Persons included in the National person Database of Restricted Persons (NDRP) d. Gaming Employment License (GEL) holders directly or indirectly involved in gaming operations e. Minors (persons below 21 years of age) Closure of gaming site 28

RG Code of Practice Version 6.0 XIII. HELP CENTERS IN THE PHILIPPINES Listed hereunder are some Help Centers located around the Philippines: Life Change Recovery Center 105 Scout Rallos St., Kamuning, Barangay Sacred Heart, Quezon City Contact: (02) 415-7964 / 415-6529 Website: www.lifechangerecovery.com Bridges of Hope Drugs and alcohol Rehabilitation Foundation, Inc. 364 Aguirre Ave., Phase 3, BF Homes, Parañaque City Contact: (02) 622-0193 / 0917-5098826 / help@bridgesofhope.com.ph Website: www.bridgesofhope.com.ph New Manila Branch: 12 Orestes Lane, Mariposa St., New Manila, Quezon City Tel. No. (02) 502-0600 Mobile: 0917-8560623 Cebu Branch: Mandaue City, Cebu 29

RG Form 5 Page No. Page 1 of 1 ON-LINE USER ACCESS Form No. GLDD-892 CONTROL FORM (NDRP) Revision No. 3 Effectivity August 7, 2023 LICENSEE NAME: _________________________________________________________ User Information Family Name First Name Middle Name Position: GEL No.: Office Tel. No.: Email: IP Address of the designated computer for NDRP access: Access Rights Property Administrator User 1 User 2 User 3 PRPD Access Agreement (Please read before signing) 1. Access account must not be revealed to others or allowed to be used by others. 2. Password must not be inserted into email messages or other forms of electronic communication. 3. Access level account must not be used to breach security permission level or interruptions to the program. Security breaches include, but are not limited to: accessing data of which the employee is not an intended recipient or logging into the program or account that the employee is not authorized to access. 4. For security and network maintenance purposes, authorized personnel from PAGCOR may monitor equipment, systems and network traffic at any time. 5. Any User found to have violated these policies may be subject to disciplinary action, which could lead to revocation of the Gaming Employment License (GEL). Authorization User: Authorized by: ____________________________________ _________________________________ Signature over printed name Signature over printed name Date: Date: FOR PAGCOR USE ONLY Confirmation Approved access by: Enrolled by: ___________________________________ ___________________________________ Signature over printed name Signature over printed name Date: Date:

RG Form 6 ENDORSEMENT FOR ELECTRONIC Page No. Page 1 of 1 Form No. GLDD-893 SUBMISSION OF PERSONAL Revision No. 1 DISCLOSURE STATEMENT (PDS) Effectivity July 12, 2023 (COMPANY LETTER HEAD) This is to endorse the filing of Personal Disclosure Statement/s (PDS) of our Board of Directors; Number of Directors (5, 7, 9, 11 or 13) Partners; Number of Partners (2, 3 or 4) Sole Proprietorship: NAME POSITION (Family Name, First Name, Middle Name) (For Consortiums, please add another column to indicate company represented by each individual) I certify that we have validated and have on record the following documents based on the latest General Information Sheet (GIS) from the Security and Exchange Commission (SEC) of the above-listed nominees of Board of Directors/Partners or the Department of Trade and Industry (DTI) Registration form of Sole Proprietor: For Filipinos and foreign residents: Income Tax Returns (ITR) duly received by the Bureau of Internal Revenue (BIR) or Certificate of Non-Filing of Annual ITR (Annex F) For non-resident foreigners: Copy of valid passports I will immediately inform PAGCOR of any change in the above listed persons upon filing of appropriate forms with the SEC or the DTI, as applicable. ___________________________ _____________________ (Signature over printed name) (Date) ______________________________ Position (Corporate Secretary/Partner/Proprietor)

RG Form 7 Page No. Page 1 of 1 ON-LINE USER ACCESS Form No. GLDD-894 CONTROL FORM (PDS) Revision No. 1 Effectivity July 12, 2023 LICENSEE / COMPANY NAME: _______________________________________________ Licensed-casino e-Games e-Bingo Instawin Poker Specialty Games User Information Family Name First Name Middle Name Position: GEL ID No.: Office Tel. No.: Email: Access Rights Administrator (for PAGCOR only) Encoder Access Agreement (Please read before signing) 1. Access account must not be allowed to be used by unauthorized persons. 2. Password must not be inserted into email messages or other forms of electronic communication. 3. Access level account must not be used to breach security permission level or interruptions to the program. Security breaches include, but are not limited to: accessing data of which the employee is not an intended recipient or logging into the program or account that the employee is not authorized to access. 4. For security and network maintenance purposes, authorized personnel from PAGCOR may monitor equipment, systems and network traffic at any time. 5. Any User found to have violated these policies may be subjected to disciplinary action, which could lead to revocation of the Gaming Employment License (GEL). Authorization User/Compliance Officer: Authorized by: ____________________________________ _________________________________ Signature over printed name Signature over printed name Position: ____________________________ Position: __________________________ (Corp. Sec./Partner/Proprietor) Date: Date: FOR PAGCOR USE ONLY Confirmation Approved access by: Enrolled by: __________________________________ ____________________________________ Signature over printed name Signature over printed name Date: Date:

Annex A PHILIPPINE AMUSEMENT AND GAMING CORPORATION NATIONAL DATABASE of RESTRICTED PERSONS Gaming Licensing and Development Department

I. OBJECTIVES 1. To establish a computerized database of persons who are restricted from entering, staying and/or playing in gaming establishments which are operated and regulated by PAGCOR nationwide 2. To make the database accessible online to authorized representatives of gaming operators 3. To deny the issuance of Gaming Employment Licenses (GEL) to restricted persons II. DEFINITION OF TERMS Casino Crime an act harmful to individuals and/or the state and committed inside the Gaming Establishment Cheat to alter the elements of chance, method of selection which determine the result of a game; the amount or frequency of payment in a game; the value of a wagering instrument; or the value of a wagering credit1 Gaming Establishment a facility which houses gaming activities operated or regulated by PAGCOR National Database of Restricted Persons or NDRP the database of excluded persons who are not allowed to enter, stay and/or play in all Gaming Establishments Gaming Operator legal entity authorized by PAGCOR to conduct gaming activities in Gaming Establishments Prohibited/Restricted Person any person who is not allowed to enter, stay and/or play in Gaming establishment under any of the following: 1) Presidential Decree 1869 as amended by Republic Act 9487 2) Malacañang Memorandum Circular No. 6 Series of 2016 3) Exclusion Order 4) GEL Holders 5) Financiers/Loan sharks III. PERSONS FOR INCLUSION IN THE NDRP The following are included in the NDRP: 1. Subject of Self-Exclusion Order - Any person granted his/her own exclusion from all Gaming Establishments 2. Respondent of a Family-Exclusion Order 1 http://www.pandullolaw.com/Criminal-Defense/Cheating-in-Casinos.aspx 2

- Any person excluded from all Gaming Establishments upon request by a qualified family member (parent, spouse, or child of at least 18 years old) 3. Respondent of a Licensee-Emanating Exclusion Order - Any person accused and proven by the Operator of any of the following offenses: Game Cheating Theft Use of camera or any electronic device to assist in projecting the outcome of the game Possession of counterfeit chips, tokens, or cashless wagering instruments Unlawful interference with a gaming equipment Forgery or counterfeiting Money laundering Fraud 4. Terminated employees by PAGCOR or any Licensee for Just Cause in the Terminated Employee Database (TED) 5. Gaming Employment License (GEL) Holders IV. ACCESS LEVELS TABLE 1 ACCESS ACCESS ROLE LEVEL FUNCTION TASK RIGHTS System 1 - User, Add, Edit, Lift, - create new user for the Administrator Excluded View and application (GLDD) Person and Update - assign IP address to specific Licensee Exclusion Order user Management - update all reference data in the system - create profile of excluded person - create profile of PAGCOR employee terminated for cause - create licensee profile - search and view present and past records in the database Property 2 - User and Add and View - create profile of excluded Administrator Guest Exclusion Order person (Licensee) Management - search and view records in the database - ensure security and confidentiality of database 3

by limiting access to authorized users only User 1 3 - User View Exclusion - search and view records in (Gaming Order the database Establishment) - add limited User 2 4 - User View Exclusion - view records in the database (Gaming Order Establishment) A. System Administrator - Gaming Licensing and Development Department (GLDD), PAGCOR 1. Shall enroll property administrators and users of the NDRP; 2. Shall maintain and update the database; 3. Shall process exclusion applications following the Responsible Gaming Code of Practice and upload the results to the NDRP; B. Property Administrator Licensee Shall treat information in the NDRP with prudence; sharing of data with any unauthorized entity is a violation of Chapter XI of the Responsible Gaming Code of Practice. The Property Administrator shall designate users for Levels 2, 3 and 4 as described in Table 1 above. V. INFORMATION CONTAINED IN THE NDRP 1. Complete Name (Family Name, First Name, Middle Name) - If no middle name, default is the entry number 2. Date of Birth (mm/dd/yyyy) 3. ID Presented - acceptable government-issued photo IDs: a) Philippine/Foreign Passport b) c) Tax Identification Number (TIN) d) Government Service Insurance System (GSIS) e) Social Security System (SSS) f) Alien Certificate of Registration/Immigrant Certificate of Registration 4. ID Number 5. Gender 6. Nationality 7. Block/House/Unit/Building Number 8. Street 9. Subdivision/Village 10. City/Province 11. Type of Exclusion 4

12. Violation / Reason for exclusion (applicable for Licensee-emanating only) 13. Exclusion Duration a. Self-Exclusion (6 months / 1 year / 5 years) b. Family Exclusion (6 months / 1 year / 3 years) c. Licensee-emanating (1 year / 5 years / Lifetime) VI. USE OF NDRP AS REFERENCE FOR ISSUANCE OR DENIAL OF GAMING EMPLOYMENT LICENSE (GEL) Licenses to Operate private casinos Through access to the NDRP, the Operator determines if an employee-applicant may be issued a Gaming Employment License (GEL). It should not endorse persons included in the database based on III.3 and 4 above (past and current Respondents of Licensee-emanating Exclusion Order, and all PAGCOR Employees Terminated for Just Cause) since this shall be ground for denial of issuance of GEL or violation of the (Provisional) License to Operate casinos. 5

A N N E X A.1 PROCEDURES A. To add a person for banning in the NDRP 1. Log in by keying in the Username and Password; 2. Accept Terms and Conditions by clicking the designated box; 3. Input the required information in the corresponding field for respondent profiling; 4. Upload the photo of the subject; 5. Upload Player Exclusion Order. B. 1. Log in by keying in the Username and Password; 2. Accept Terms and Conditions by clicking the designated box; 3. fields only (alias/es, distinguishing marks and comments). C. To search/verify if a person has a valid Exclusion Order as listed in the NDRP 1. Log in by keying in the Username and Password; 2. Accept Terms and Conditions by clicking the designated box; 3. Designated officer/staff types in the full name of the guest to view the subject . In case there is a match in the database, the identity of the subject can also be verified through the Birthdate Address Nationality Date of banning Gaming establishment Alias Distinguishing mark Crime violated (for licensee-emanating) D. To view an excluded person in the NDRP 1. Log in by keying in the Username and Password; 2. Accept Terms and Conditions by clicking the designated box; 6

3. The page will automatically display a gallery of the excluded persons. E. To lift the Exclusion Order of a person in the NDRP All exclusion orders shall automatically be lifted by the system upon expiration of their exclusion period. Information on the restricted person will no longer be displayed in the database but the System Administrator may retrieve information through historical data. Only the System Administrator (GLDD) has the authority and access to lift an Exclusion Order. This may be done only for the following reasons: 1. If upon verification, the ground for Licensee-emanating Exclusion Order is not included in the list under Chapter XI.c and is therefore a deviation from the NDRP guidelines; 2. If in the course of audit, it was discovered that pertinent documentary requirements on file are incomplete; 3. If #1 reason is satisfied, the respondent is endorsed by an Operator for employment in his Gaming Establishment; 4. If there is a request for a petition to amend the Exclusion Order, whether self, family, or Licensee-emanating exclusion order. Hereunder is the procedure: a) Log in by keying in the Username and Password; b) Accept Terms and Conditions by clicking the designated box; c) Input the required information in the appropriate fields for lifting d) Once lifting order has been made, the subject the NDRP 7

Annex B Personal Disclosure Statement (PDS) Electronic Application Guide I. OBJECTIVES 1. To establish a database of the Philippine gaming Board of Directors, Partners and Sole Proprietors. 2. To facilitate annual submission of the Personal Disclosure Statement (PDS) through an electronic system. 3. To make the database accessible through the web to authorized users. II. DEFINITION OF TERMS Board of Directors a group of individuals that are elected as, or elected to act as, representatives of the stockholders to establish corporate management related policies and to make decisions on major company issues1 Corporation an association of individuals, created by law or under authority of law, having a continuous existence independent of the existences of its members, and powers and liabilities distinct from those of its members2 Partnership is an arrangement where parties, known as partners, agree to cooperate to advance their mutual interests3 Personal Disclosure Statement (PDS) personal and financial information certified true by the members of the Board of Directors, Partners and Sole Proprietors of PAGCOR-authorized gaming entities PDS Database a compilation of personal information as provided by the nominees of the Board of Directors, Partners and Sole Proprietors of PAGCOR-licensees Sole Proprietorship an individual who is the sole owner of the business that is neither a partnership nor a company4 1 http://www.investopedia.com/terms/b/boardofdirectors.asp 2 http://dictionary.reference.com/browse/corporation 3 http://en.wikipedia.org/wiki/Partnership 4 http://www.bing.com/search?q=definition+of+sole+proprietor&src=IE-TopResult&FORM=IE11TR&conversationid=

III. LICENSEE S ACCESS TO PDS ONLINE APPLICATION A. Corporation One (1) Compliance Officer is officially designated by management through RG Form 7 to input information on the nominees of the Board of Directors into the PDS database system, and to point of contact. His/Her contact details (email address and telephone number) must be provided. B. Partnership 1 Partner may input his information into the PDS database system or a Compliance Officer may be officially designated through RG Form 7. C. Sole Proprietorship / Partnership The Owner will personally input information into the PDS database system through RG Form 7. IV. ACCESS LEVELS AND FUNCTIONS Table 1 ACCESS ACCESS ROLE FUNCTION TASK LEVEL RIGHTS PDS Super 1 - User, PDS -view, verify and - enrol PDS Users Administrator system print PDS (GLDD) management applications -edit erroneous entries PDS Administrator 2 - User -view PDS - search and view (GLDD) information information, generate and print PDS reports PDS Encoder 3 - User/Encoder -encode required -input data and (Licensee/Operator) PDS information submit electronically A. Super Administrator - GLDD, PAGCOR 1. Enrolls users/encoders who are authorized to access the PDS system; 2. Maintains PDS database system; 3. Analyzes, generates and prints PDS reports, as needed. B. Administrator - GLDD, PAGCOR 1. Views information on licensees PDS; 2. Determines completeness of submitted documents and compliance to renewal requirements; 3. Generates and prints PDS reports, as needed. 2

C. Encoder Licensee/Operator 1. Inputs required information in the PDS system on behalf of the partners and sole proprietor and promptly submits the form upon completion; 2. Treats information in the PDS with prudence; sharing of data with any unauthorized entity is a violation to the Terms and Conditions of the PDS system; V. MANDATORY INFORMATION CONTAINED IN THE PDS 1. Complete Name (Family Name, First Name, Middle Name) 2. Alias 3. Date of Birth (mm/dd/yyyy) 4. Nationality 5. Tax Identification Number (TIN) for Filipino citizens and Foreign residents or Valid Passport details for non-resident Foreigners (number, place of issuance and expiry date) 6. Contact Information Address Telephone/Mobile number Email address Relatives in PAGCOR, if any 7. All affiliations with PAGCOR licensees 8. Integrity and financial soundness 9. Professional history 10. Declaration and confidentiality VI. PROCEDURE A. To access the PDS system: The Compliance Officer must fully accomplish and submit the Endorsement for PDS Application form (RG Form 6) and PDS User Access Control Form (RG Form 7) to obtain access to the PDS System. He/She must completely list down the names of all directors, partners or proprietor in RG Form 6, consistent with the latest forms filed with Securities and Exchange Commission (SEC) or Department of Trade and Industry (DTI). B. To fill up and to submit the electronic PDS form (Refer to Diagram 2): 1. Log in by keying in the Username, Password and Captcha; 2. Accept Terms and Conditions by clicking the designated box; 3. directors per Licensee; 4. Click the 5. Click the ; 6. Input the required information accurately into the corresponding fields; 7. Verify the correctness/completeness of information; 8. Create icon to save and submit PDS application. 3

Note that submission will not proceed if: a) any of the mandatory fields are blank: and b) at least one (1) PDS form of any of the directors or partners is either blank or incompletely filled up Compliance is based on complete submission by all nominees of the Board of Directors, Partners and Sole Proprietor. C. To search/verify if an applicant is in the PDS database: 1. Log in by keying in the Username, Password and Captcha; 2. Accept Terms and Conditions by clicking the designated box; 3. Click the 4. and search for members per business type, in the Note that a Compliance Officer can only view his/her PDS data. D. To print PDS reports (for Administrators only): 1. Log in by keying in the Username, Password and Captcha; 2. Accept Terms and Conditions by clicking the designated box; 3. 4. Choose the report per classification; 5. VII. REMINDERS FOR SUBMISSION A. Annual Submission Electronic submission of the PDS must be done from January 1 to May 31 of every calendar year by the nominees of the Board of Directors of the licensees, sole proprietors and partners. All data submitted through the PDS electronic system cannot be edited and are considered valid, true and final. B. Late Submission PDS forms submitted after the May 31 deadline will be tagged as late. This will be the basis for penalties as provided in the Regulatory Manuals. 4

C. Updates after Deadline PAGCOR must be informed of any change in the composition of the Board of Directors, partnership or sole proprietorship through the immediate submission of copies of Security and Exchange Commission (SEC) or Department of Trade and Industry (DTI) forms to the GLDD office. Updates on the electronic PDS database must be made during the submission period of the succeeding year. D. Manual Submission Gaming License / Authority to Operate / Certificate of Registration will be accomplished manually (refer to www.pagcor.ph/regulatory/cegs.php). 5

Annex C GS FORM NO. 33 (v.1) 04.30.2015 GLDD Reference No. ______________ CERTIFICATE OF NON-FILING OF ANNUAL INCOME TAX RETURN (Board of Directors) NAME COMPANY NAME TYPE OF GAMING ACTIVITY Electronic Games Bingo Games Poker Games GAMING SITE ADDRESS I hereby certify that I did not file my Income Tax Return (ITR) for CY _____, as prescribed under the provisions of the NIRC of 1997 and its amendments Title II Chapter IX, Sec. 51.A.2. Attached are the pertinent documents to support my claim: ___________________________________________________________________________________ ___________________________________________________________________________________ ___________________________________________________________________________________ Signature: _____________________ Date: ______________ IN WITNESS WHEREOF, this certification has been signed this ___ day of ___________ , 20____ at _____________, Philippines. SUBSCRIBED AND SWORN to before me, a Notary Public and in the City/Municipality of _________, Philippines, personally appeared _________________ with his/her Identification No. ______________ issued at _______________ on ___________, known to me to be the same person who executed the foregoing instrument and acknowledged to me that the same is his/her own free and voluntary act and deed. Doc. No. ___________________; Page No. ___________________; Book No. ___________________; Series of 20__.

Diagram 1 Employee Verification Flowchart LICENSEE GLDD (Authorized (CDSPA Unit) Officer/HR) Fills out RG Form 1 Checks (Employee completeness of Verification Form) RG Form 1 Submits to GLDD Verifies information in the GEL Database Conducts Returns investigation if the accomplished RG employee violated Form 1 to Licensee his/her employment contract provision Submits GEL Form F Processes (Notice of Employee GEL Form F Separated for Cause) Adds respondent to Terminated Employees Database Process Flow: 1. Authorized Officer/HR fills out and submits RG Form 1 to request verification of employee from PAGCOR GLDD. 2. GLDD checks the completeness of information in the submitted form. 3. GLDD verifies the status of the subject employee in the GEL database. 4. GLDD returns the accomplished form to the Licensee after verification. 5. Licensee conducts full investigation to prove that the employee violated employment contract provision or company policy on prohibition from playing in a gaming establishment. 6. If proven, the Licensee submits the GEL Form F and keeps pertinent documents on file. 7. GLDD processes Notice of Employee Separated for Cause. 8. GLDD adds respondent to Terminated Employees Database.

Diagram 2 How to Submit PDS Electronically? 1. Log in by keying in the Username, Password and Captcha; 2. Accept Terms and Conditions by clicking the designated box. 3. 4. 5. Input the required information in the corresponding fields; 6. .

Diagram 3 COMPLIANCE VERIFICATION DIAGRAM Start Send notification or GLDD issues Notice of on the spot RG Non-Compliance to Compliance Licensee Verification PAGCOR Licensee resolves representatives GLDD findings explain the process and scope of activity to Licensee Licensee submits documents/proof of compliance to GLDD PAGCOR representatives will Complied check gaming area and NDRP for compliance End PAGCOR representative will discuss the result of the inspection base on the RG compliance report Complied? No Yes End

Diagram 4 IMPOSITION OF PENALTY FLOW CHART