• We do not cash welfare or unemployment checks.
• We have a process to honor the requests of customers who wish to be denied access to our casinos, and that their access to credit, check-cashing, and casino promotions be restricted.
• We display toll-free helpline numbers for problem gambling in our ads, brochures, and signs, and we provide financial support for those helplines.
• We train our employees to understand the signs of problem gambling and empower them to provide customers with information describing how to get help.
• We emphasize to our employees that casino gaming is an appropriate activity for adults only, and require them to be vigilant in their efforts to prevent individuals under the legal age from playing at our casinos.

• We invest in our employees by providing excellent pay and valuable benefits, including health insurance and a retirement plan.
• We are committed to sharing our financial success through programs such as cash bonuses for frontline employees.
• We encourage professional and personal growth through tuition reimbursement, on the job training, career development, and promotion from within.
• We actively seek and respond to employee opinions on all aspects of their jobs, from the quality of their supervisors to the quality of our casinos.

• We conduct our business with honesty and integrity, consistent with the highest moral, legal, and ethical standards, complying with all applicable laws and regulations.
• We share our financial success with our communities by donating one percent of company profits to civic and charitable causes.
• We encourage our employees to volunteer in civic and charitable causes.
• We restrict the placement and content of our advertising and marketing materials.

Millions of responsible adults enjoy the excitement of casino gaming at a Harrah�s Entertainment, Inc. property each year.  Casino customers by and large treat casino gaming the same way they treat other forms of recreation: they budget the time and amount of money they want to spend, and they consider their chosen recreation a pleasant pastime, not a way of life. We�re proud that we entertain millions of customers each year in our casinos. Our customers overwhelmingly tell us that they have fun at our casinos, whether they win or lose on any particular occasion.

Promoting responsible gaming is part of our culture at Harrah�s. Our long-standing position has been that if a customer plays at a Harrah�s casino (operated under the Harrah�s, Rio, or Showboat brands) for any reason other than the fun of it, that customer is playing for the wrong reason. Many observers have lauded Harrah�s industry-leading programs and practices in combating problem gambling.

The advertising and marketing of our casinos must be sensitive to these issues and also be truthful and reflect generally accepted standards of good taste.

In furtherance of these interests and in recognition of Harrah�s strong opposition to irresponsible or inappropriate gambling, Harrah�s has adopted this Code for its marketing and advertising.

Scope

1. The Code applies to the marketing and advertising of all Harrah�s Entertainment, Inc. brands and properties: Harrah�s, Rio, and Showboat.
2. The Code applies to every media or channel for marketing and/or advertising, including direct mail, outdoor, in-casino, radio, television, print, and Internet. 
3. The Code does not apply to educational materials, broadcast messages, or Internet content designed specifically to address the issues of underage or problem gambling. 
4. Harrah�s complies with all local laws and regulations regarding marketing and advertising. These local laws and regulations may include limitations, restrictions, or other provisions that are different from those identified in the Code. In such cases, the local laws and regulations supercede the Code.

Content

5. Advertising and marketing materials portray casino gaming and casino customers in a responsible manner. Advertising and marketing materials are designed for adults who choose to play casino games. 
6. Advertising and marketing materials are consistent with contemporary local standards of decorum and decency. They do not use religious themes, figures, or symbols.  Nor do they degrade the image, form, or status of women, men, or any ethnic, minority, or other group.
7. Advertising and marketing materials do not depict, encourage, or condone excessive, irresponsible, or illegal gambling.

They do not:

7.1. State or imply that casino gambling is an acceptable means of satisfying work or family commitments, or an alternative to work or family commitments;
7.2. State or imply that casino gambling is necessary for financial, physical, or social success;
7.3. State or imply that casino gambling solves personal problems;
7.4. Portray individuals who are intoxicated, who are compelled to gamble, who have lost control of their facul-ties, or who have become separated from reality; or
7.5. Suggest in any way that excessive, irresponsible, or illegal gambling is an amusing or acceptable behavior.

8. We only advertise and market our brands and casinos to adults above the legal age to gamble in a casino. Our marketing and advertising materials do not:

8.1. Show casino gambling being experienced by anyone under the legal age;
8.2. Use actors who are below 25 years of age or who reasonably appear to be below the legal age to gamble in a casino;
8.3. Use any symbol, language, gesture, cartoon, music, animated character, entertainment figure, or child�s toy that has primary appeal to persons below the legal age to gamble in a casino. Material has a �primary appeal� to persons below the legal age to gamble in a casino if it has special attractiveness to such persons above and beyond the general attractiveness it has for persons above the legal age to gamble in a casino.
8.4. Show or imply that casino gambling is a �rite of passage� or otherwise necessary for the attainment of adult-hood. 

Placement

12. We do not promote our brands or casinos at any event where the majority of the audience is reasonably expected to be below the legal age to gamble in a casino. This does not prevent us from erecting advertising or marketing at or near facilities that are used primarily for adult-oriented events, but which occasionally may be used for an event where most attendees are under the legal age to gamble in a casino.
13. No product name, logo, trademark, or service mark is used or licensed for use on clothing, toys, game equipment, or other materials that are intended primarily for persons below the legal age to gamble in a casino. Materials that are intended primarily for persons below the legal age to gamble in a casino, regardless of the presence of any product name, logo, trademark, or service mark, are not used as promotional materials or are given away at events, except in response to a charitable request.
14. Advertising and marketing materials are not placed in magazines, newspapers, television programs, radio programs, or other media where more than 30 percent of the audience is reasonably expected to be below the legal age to gamble in a casino.
15. We do not advertise our products or brands in college or university newspapers.  Advertisements elsewhere in college or university media are in conformity with policies promulgated by appropriate college officials or with the prior approval of appropriate college officials. 
16. We do not advertise on the comic pages of newspapers or magazines. 
17. New advertising is not placed on any outdoor stationary location within 500 feet of an established place of worship or an elementary school or secondary school. If existing advertising is within 500 feet of said locations, contracts for its placement will not be renewed.
18. We are particularly sensitive about the use of the Harrah�s website. We:

18.1. Post that the website is designed for individuals who are of legal age to gamble in a casino.
18.2. Take appropriate precautions to ensure that visitors to the play for fun casino are 21 or older.
18.3. Include messages discouraging underage and irresponsible gambling.  
18.4. Include information on our website about our responsible gambling philosophy, practices, and programs.

19. A copy of this code is given to every casino employee and outside agency whose responsibilities include advertising and marketing, as well as to any outside party who might request it.
20. A Code Review Board comprised of Harrah�s employees meets at least annually and evaluates Code compliance. The Board reviews current recognized electronic and print composition data in order to insure that advertisements are placed in compliance with the Code. The Board prepares an annual written report outlining the extent of Code compliance and, if necessary, describing means to ensure greater Code compliance. 
21. The Board also meets when necessary to consider complaints about Harrah�s marketing or advertising materials lodged by any interested party. If clear, objective evidence demonstrates to the Board that any advertising or marketing material is in violation of the Code, the material in question will be withdrawn.  All complaining parties are notified of the resolution of their complaints.

Effective Date

22. The provisions of this Code apply to any marketing or advertising activity undertaken on or after January 1, 2001.

© 2000 Harrah�s Entertainment, Inc. October 2000