Company profile. GLI Austria GmbH Riesstraße Graz AUSTRIA. Page 1 von 28

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1 Gaming Laboratories International Company profile GLI GmbH Riesstraße 146 AUSTRIA Page 1 von 8

2 WHERE THE GAME BEGINS... 3 About GLI GmbH Office location in... 3 Services offered... 4 GLI Standards... 4 Clients... 5 Worldwide ISO Accreditations... 9 Device and Data Storage... 9 Protection of Information and Data... 9 MANAGEMENT Overview The GLI Testing and Certification Process Submission Processing Pretest Review General Testing Guidelines Testing Objectives... 1 GLI Test Procedures... 1 Equipment and Software Selection of Tasks Performed During Testing General Testing Tasks Specific Testing Performed by GLI Main Program Testing Personality/Data Program Testing Associated Software Testing Hardware Testing Protocol, Progressive and Ticketing System Testing Technical Review Report Processing/Quality Assurance Mailing and Updating Archive Visual Outline of the GLI Submission Process GLI Math Overview Randomness, Probability and Fairness Testing... 0 Evaluation of Theoretical Return to Player (RTP)... 0 Random Number Generator (RNG) Analysis... 0 Chi-Square Test... Serial Correlation Test... 3 Interplay Correlation Test... 3 Runs Test... 3 Other Services... 4 On-Site Inspection and Certification... 4 Consulting Services... 4 Training Services... 4 Day-to-Day Operational Services... 5 Drafting IT Solutions... 5 Forensic Evaluation... 5 GLI GmbH. Page of 8

3 WHERE THE GAME BEGINS About GLI GmbH. GLI GmbH., located in Graz, is an independent organization serving European and international markets as part of the Gaming Laboratories International (GLI) network of companies. This global network was founded in 1989 by James Maida and Paul Magno as the first privately owned organization of its kind in the world dedicated to offering independent consulting, testing, inspection and certification services in the gaming and casino technology fields for regulatory markets worldwide. GLI was initially established in, to address the integrity concerns of European regulators resulting from the rapid growth of gaming throughout the European community. The office has since undergone several major expansions, and is currently staffed by over 6 test engineers and numerous additional administrative and technical support employees. Our facility, centrally located in Graz,, occupies approximately 400 square meters of testing floor space, suitably equipped to test the integrity of all types and categories of gaming devices and systems, as well as their ability to operate with each other. GLI 's reputation for integrity, quality, competence and independence is accepted by regulators throughout the European gaming world. As a result, we have been retained by numerous European jurisdictions to either test or provide gaming related consulting services. These jurisdictions include, among others,, Belgium, Croatia, Denmark, Finland, Germany, Greece, Iceland, Italy, Latvia, Lithuania, Luxemburg, Malta, The Netherlands, Norway, Russia, Slovenia, South Africa, Spain, Sweden, Switzerland and The United Kingdom. Doing business with GLI gives our customers access to the support of a global network of eight other offices spanning North America, South America, Africa, Australia and Asia. This network, relied on worldwide by over 400 jurisdictions, is comprised of approximately 500 employees, including several hundred test engineers as well as technical and administrative support personnel, quality control regulatory specialists, mathematicians, accountants and attorneys. Our team is dedicated and well equipped at all times to assist customers with every facet of regulated gaming, including the selection, placement and use of gaming devices from legislation to laboratory testing to final field inspection and auditing. Office location in GLI GmbH. Rießstrasse 146 GLI GmbH. Page 3 of 8

4 Services offered GLI offers Independent Testing, Inspection, Certification, Forensic Analysis, Protocol Analysis and Consultation Services, which includes, but is not limited to: Gaming Devices in casinos Video Lottery Terminals (VLTs) Gaming device peripherals (currency acceptors, printers, card readers, etc.) The development of standards to monitor gaming activity Electronic Table Games Electronic Bingo and Keno devices and systems Finite scratch ticket and pull-tab systems Charitable gaming devices and systems Progressive systems/signs Gaming and Lottery Systems Onsite Inspections Auditing Training Consultation Internet Gaming Equipment, Devices and Systems GLI Standards GLI has authored and published the following series of standards, which are widely accepted and used by gaming regulatory agencies. GLI does not necessarily perform accredited testing for regulatory compliance to all of the standards listed below. The list is provided for reference should a request for certification against our already published standards. The latest versions of the GLI Standards series may be obtained by contacting us or downloading them from our website at GLI-11 GLI-1 GLI-13 GLI-14 GLI-15 GLI-16 GLI-17 GLI-18 GLI-19 GLI 0 GLI-1 GLI- GLI-3 GLI-4 GLI-5 GLI-6 GLI-7 GLI-8 Gaming Devices in Casinos Progressive Gaming Devices in Casinos On-Line Monitoring and Control Systems Electronic Bingo and Keno Systems Electronic Bingo and Keno Systems Cashless Systems in Casinos Bonusing Systems in Casinos Promotional Systems in Casinos Internet Gambling Environments Redemption Kiosks Server-Based Game Download Systems Class II Electronic Bingo Systems Video Lottery Terminals Electronic Table Game Systems Dealer Controlled Electronic Table Games Wireless Gaming Systems Network Security Best Practices Player User Interface System Note: GLI must maintain independence and impartiality in order to provide service as an accredited organization with the highest level of integrity. We cannot and will not engage in the production or design of products upon which we provide service. GLI GmbH. Page 4 of 8

5 Clients GLI GmbH. provides quality independent consulting, testing and evaluation services to manufacturers, operators, and regulators within the gaming, wagering and lotteries industry. Typical clients are from: Gaming Commissions & Enforcement Agencies throughout Europe Lottery Commissons & lottery operators math, audits and regulatory testing for suppliers Albania Land based igaming Alderney Andalusia Aragon Asturia Balear Belgium NJMF Albanian Regulatory Agency Alderney Gambling Control Commission Andalusia Board General Directorate of Entertainment Public Games & Recreation Government of Aragon General Council of Interior Ministry of Presidency, Justice and Equity Asturias Princedom Carinthia, lower Ministry of Interior - General Directorate of Interior Balear Government Gaming Commission Metrology Division Service Jeux de hasard The Canary Islands Ministry of Presidency, Justice and Security - General Directorate of Territorial Administration and Governance Canary Islands Government GLI GmbH. Page 5 of 8

6 Cantabria Castilla y Leon Castilla La Mancha Catalonia Ceuta Croatia Denmark Estonia General Secretariat of the Presidency and Justice Government of Cantabria Department of Presidency and Justice Ministry of Interior and Justice - General Directorate of Public Entertainment and Recreation in the Community of Castilla y León Castilla y León Board Administrative Permissions Ministry of Economy and Finance. Castilla-La Mancha Board Catalonia Board Department of Interior General Directorate of Gaming and Entertainment - General Secretariat Ministry of Finance Ministry of Finance, Tax Administration Danish Gaming Board Ministry of Finance of Estonia Extremadura Galicia Extremadura Board Ministry of Finance and Budget Directorate General of Revenue Ministry of Public Administration and Justice General Directorate of Public Entertainment and Game Galicia Board GLI GmbH. Page 6 of 8

7 Gibraltar Greece Iceland Italy Isle of Man Latvia Lithuania La Rioja Macau Madrid Malta Melilla Gibraltar Regulatory Authority (GRA) Greece Gaming Board University of Iceland Lottery Amministrazione Autonoma dei Monopoli di Stato (AAMS) Isle of Man Gambling Supervision Commission Latvian Lotteries & Gaming Supervisory Inspection State Gaming Control Commission Ministry of Finance - Directorate General of Taxes Government of La Rioja Macau Gaming Commission Madrid Community Ministry of Presidency Directorate General of Planning and Management of Games Lotteries and Gaming Authority Ministry of Finance GLI GmbH. Page 7 of 8

8 Murcia Navarre Baskenland San Marino Singapore Slovenia Sweden Switzerland Netherlands United Kingdom Ministry of Finance and Public Administration - Directorate General of Taxes Murcia Region Department of Presidency, Justice and Home Affairs Government of Navarre Ministry of Interior - Department of Game and Spectacular Events Basque Government State Agency of the Games of San Marino Singapore Casino Regulatory Authority State Office of Gaming Supervision Swedish National Gaming Board Switzerland Federal Gaming Board Ministry of Justice Gambling Commission Valencia Ministry of Economy, Finance and Employment Valenciana Community GLI GmbH. Page 8 of 8

9 Worldwide ISO Accreditations Gaming Laboratories International operates 9 fully accredited testing laboratories worldwide in addition to fully accredited inspection bodies in North America, Europe and Africa. GLI is the only independent testing organization of its kind to hold both U.S. and International accreditations for compliance with ISO 1705 and 1700 standards for technical competence in testing and inspection services. Accredited for compliance with the following standard: ISO/IEC 1705:005 "General requirements for the competence of testing and calibration laboratories" ISO/IEC 1700:1998 "General criteria for the operation of various types of bodies performing inspection" GLI Facility Accredited - Registered Standards USA -New Jersey (HQ) 1705/1700 ALA Accreditation Body Scope ID Colorado 1705 ALA Las Vegas 1705 ALA Netherlands 1705/1700 RvA L37/I111 Italy 1705/1700 RvA L496/I / BMWA - TUV South Africa 1705/1700 SANAS T0143/INSP0007 Australia - Sydney NATA - NCS Australia - Adelaide NATA - NCS Earning and maintaining accreditation to ISO standards affirms the integration effective quality management practices and the technical competency of GLI services. Operating as an accredited organization requires GLI operational, technical and administrative procedures to be independently evaluated against industry-standard practices for quality, technical proficiency and service to the customer. Device and Data Storage All GLI facilities and GLI GmbH. in particular have adequate space for storing and protecting Gaming machines regardless of whether they are currently under test. Our facilities have procedures to control machine inventory and handling. Software media is stored in a secure location with the lab, which is monitored 4 hours a day seven days per week. It also has restricted access by only a few personnel. Software is categorized and tracked by the submission assigned to the project and the software ID. Protection of Information and Data All records are the confidential property of GLI and are only shared with other GLI companies except where required by legal statute, contractual agreement or a management directive. GLI does not permit third party disclosure of client confidential information without taking appropriate precautionary measures as directed by our General Counsel. Regulatory clients may review technical or quality records relevant to work performed on their behalf onsite during normal hours of operation. Suppliers may review technical or quality records related only to their items tested onsite during normal hours of operation. GLI GmbH. Page 9 of 8

10 In addition to conducting routine employee background checks, GLI equips its computer systems and facilities with security and monitoring equipment to prevent unauthorized access to records. All GLI facilities are equipped with the necessary security access control and monitoring to prevent access by unauthorized individuals. Network and computer access is controlled and monitored by the IT department. MANAGEMENT Overview GLI 's staff is comprised of engineering, quality assurance, business development, compliance and other operational personnel. Engineering technical managers are responsible to ensure adequate assignment and accurate execution of all technical tasks by suitably trained test engineers. They report to the Director of Engineering in all matters relating to technical operation, project statuses and resource requirements in the organization. Engineering, quality assurance and all other operational staff members are accountable to their manager and the Managing Director, who has ultimate responsibility for the operation of the organization. Test engineers follow an apprenticeship and active employee development program which establishes their progression into three tiers. These are Test Engineer Level I, Test Engineer Level II and finally a Senior Engineer. Promotion is based on regular assessments of their technical product knowledge, performance and project management skills. The quality assurance personnel are responsible for the review of completed engineering documentation for accuracy and completeness. Following this review, they prepare and issue reports to customer specifications. The quality assurance staff is knowledgeable of the gaming industry as well as the technical standards and requirements for which the report is being prepared. The compliance staff is comprised of a Quality Systems Controller who interfaces with the technical compliance and regulatory compliance staff members located at GLI Headquarters. GLI GmbH. Page 10 of 8

11 The GLI Testing and Certification Process Submission Processing GLI GmbH. has developed an electronic database used to track projects submitted for work. This allows effective management of the workflow and approval lifecycle of all work submitted to GLI GmbH. When the work is completed, reports are made available to customers via secure login on our website. Submissions are initially received and processed by our submission staff members. These staff members are part of our Quality Assurance department. They review the work requests submitted to GLI GmbH. along with supporting documentation for accuracy and completeness. They enter all information needed to identify and categorize the item in the GLI Submissions Database and consult with the Technical staff members if further clarification is needed. Any relevant electronic signatures used to authenticate software are also entered into the database record where applicable. Pretest Review After all signatures have been obtained and/or verified, the information is entered into the database, the submission is prepared for routing to an engineering Technical Manager or Senior Engineer. This individual reviews the work to be done and determines which engineer will perform the testing, which testing tasks will need to be done and how much time will be allocated for these tasks. Tasks are assigned through our project tracking system that is integrated into the GLI Submissions Database. Tasks requiring the work of a GLI mathematician to evaluate the game concept, payout tables, RNG functions, game volatility or theoretical return percentage paid to game players are forwarded to the GLI Math department along with any required information. (See GLI Math Department Functions.) General Testing Guidelines Test engineers review the submission documentation and tasks to be performed. They then perform testing of the submission in accordance with the tasks assigned by the Senior Engineer or Technical Manager. Any abnormal conditions, results or nonconformities are documented and resolved with senior staff members, Technical Compliance personnel, Quality Assurance personnel and suppliers. Completed test results are finalized and recorded on various check off and cover sheet forms. All GLI service logic strives to provide independent and impartial verification that a submitted item complies with functional expectations and regulatory requirements. GLI GmbH. Page 11 of 8

12 Testing Objectives Our testing intends to meet two objectives: The first objective is to ensure the submitted game software or hardware functions properly within the gaming test environment. The gaming test environment consists of the gaming machine itself, associated software, hardware, peripheral devices, and communications required to simulate the way a game will operate in the field. The level of functionality testing has been determined by a common expectation of operational standards in the Gaming industry in addition to the training and experience of GLI test engineers. The second objective is to ensure that a submission complies with the specific technical requirement and standards set by the governing regulatory commission for which the supplier is requesting approval. GLI Test Procedures GLI testing and math procedures are proprietary to the organization and kept in controlled document libraries. GLI does not allow their distribution outside of the organization. GLI will allow procedures to be reviewed on our premises. GLI has an extensive library containing hundreds of documents and specific testing procedures that will vary between manufacturer, platform, item functionality and any jurisdiction specific test scripts. Please note: The list of testing procedures contained in this document is not a complete listing of all procedures contained in our document libraries. The document titles listed are to help provide clarification of its purpose and may not be an exact match of the title listed on the document itself. The general test procedures related to our testing are listed below: Machine Hardware Test RNG: Random number Generator Analysis Error/Event Handling Accounting Accuracy Communications Interface: Bill Validator/Acceptor Communications Interface: Progressive Controller Communications Interface: On-Line System Protocol Paytable Percentage Evaluation Paytable Emulation Source code review Time per Game Measurement Prize Calculation Support Software Media Operation Systems Security Access Systems Significant Events Systems code Comparison & Compilation Systems communication Intermediate Unit to Machine Interface Systems Reporting Jurisdictional Regulations Review On-Site Casino Inspection GLI GmbH. Page 1 of 8

13 Equipment and Software GLI uses the following items to perform testing tasks: The appropriate gaming machine and software to create the test environment Source code comparison/analysis software Applicable software compilers SAS Protocol simulation software and associated scripts Test PC Stopwatches Emulation programs and equipment Oscilloscopes Multimeters AC Power Source Exactomizer program Optimizer program Microsoft Excel GLI uses a handheld electrostatic discharge device to simulate cheating techniques observed in the field. This test is performed to assess the ability of a Gaming device to recover from this type of static discharge. Signature Verification Tools and Software GLI Verify GLI SFCK Kobetron GI-3000 Kobetron MT-000 Dataman S4 Dataman Vali-FLASH Kobetron LT-400 Selection of Tasks Performed During Testing GLI will select and apply the documented procedures that are most appropriate to properly test an item submitted. The testing tasks and procedures performed by GLI will overlap as needed to help ensure that an approved item has met all requirements. The three main contributing factors to the selection of testing tasks for items submitted are explained below: Expected functionality: Gaming device operation is comprised of the integrated function of all hardware, software and communication with a system. This also makes up the test environment under which functionality, compliance, protocol and interoperability testing is conducted. For example, new ticket printing software cannot be tested without also testing the ability of the game to accept a printed ticket and update the appropriate game meters. There is also protocol communication involved in this process to ensure an accounting system receives the accurate information about the ticket printed and inserted. This activity may involve the functional integration of the printer software, main program, bill acceptor software and sometimes communications software that is not part of the main program. Therefore, all testing tasks related to the expected overall functionality of the device will be selected as an experienced engineer feels it is appropriate to the item submitted GLI GmbH. Page 13 of 8

14 Manufacturer Design Differences: There are also design differences between manufacturers and between game platforms. For example, some main programs will have integrated personalities and some associated software programs may have an influence on the possible outcome of a game. This would also require the selection of testing tasks that are applicable to both types of programs. This is again determined based on an initial review of a submission performed by one our trained engineering staff members with expertise in understanding the manufacturer s product design. Regulatory Requirement Differences: Gaming regulatory agencies are often required to tailor technical requirements to meet the needs of their specific jurisdiction. In order to provide the proper service, GLI also tailors the selection of testing tasks and methods. This helps to provide better assurance that an item approved was properly tested against the specific regulatory requirements. General Testing Tasks The following is a general list of testing tasks that may be selected when GLI receives a submission. Testing tasks are not limited to the items in this list. The specific test procedures used will depend on the item submitted. General functionality Compatibility testing Game recovery from errors and interruptions Program source code review Comparison with a previously approved version of a modified program Math analysis Emulation of the payout tables including bonus features Game meter verification Communication/Protocol testing Payglass, Help Screens and Artwork and Game Description verification Progressive configuration and support (i.e. # of progressive levels) Control program integrity check Software Modification comparison with a previously approved version Ticket testing (TITO) Printer testing Bill acceptance/cheating techniques Coin acceptance/cheating techniques Error conditions RNG implementation Advanced features (EFT/AFT etc.) GLI GmbH. Page 14 of 8

15 Specific Testing Performed by GLI Main Program Testing This software testing generally involves verifying the critical functions of a game such as control program functions, memory management, metering, error messages, communications, implementation of the RNG, advanced features and control of peripheral devices. Other testing tasks may be applicable based on the item. Personality/Data Program Testing A personality program generally involves testing the payout tables, bonus game payouts, progressive support, and the functional operation of the software as it is integrated with the main program. Other testing tasks may be applicable based on the item. Associated Software Testing Associated software typically refers to programs used to operate sound, graphics, peripheral devices, communications and some other functions not controlled by the main program. Testing generally involves verifying that it functions as intended, integrates properly with the main and personality programs, and does not cause misleading or inappropriate events to occur that would adversely affect a gaming device or system. Other testing tasks may apply based on the item. Hardware Testing Hardware testing generally involves verifying the compliance and expected operating performance of an electromechanical device, its parts, or components within the game testing environment. This scope of this type of testing ranges greatly. Tasks are selected based on specific hardware device submitted and any applicable software included. The procedures and test scripts used will follow the assigned tasks for functionality, communication and compliance testing. Hardware testing can involve but may not be limited to any combination of the following: Modifications to a machine or peripheral device Testing an entirely new Gaming machine all related software and peripherals Kiosks and related software Peripherals such as printers, coin acceptors, bill acceptors, display terminals etc. Card shufflers Top Boxes and related software GLI has designated appropriate categories in which to classify and track the various types of hardware. GLI GmbH. Page 15 of 8

16 GLI generally regards any software used within hardware devices as associated software unless its function is more appropriately characterized as a main or personality program by the manufacturer specifications or an engineer s evaluation. Software installed within hardware peripherals may also be referred to as firmware. Protocol, Progressive and Ticketing All GLI facilities are capable of performing communication protocol testing, ticketing (TITO), and progressive testing on Gaming devices received for testing. The tasks and procedures are briefly described below. Additional testing tasks are assigned based on the specific item submitted for testing. SAS Protocol Testing SAS testing is performed in accordance with GLI internal procedure SAS Test Work Instruction. This process uses SAS host simulator software installed on a test computer to simulate commands and messages between a SAS system and the device being tested. Our standard procedure is to perform protocol testing when a device s specifications indicate that it supports a communications protocol used in Gaming. GLI will also perform protocol testing when there is a regulatory requirement to do so. Once a game has passed full protocol testing, GLI will perform partial testing on subsequent revisions where the software. This process uses source code analysis and comparison software to identify the areas where the code related to communications protocol has been changed. Once the changes have been identified, testing is only performed on the areas affected. SDS Protocol Testing Although the SDS protocol is seldom used, GLI does perform SDS testing on games capable of supporting the use of this protocol. Progressive Testing GLI performs functional progressive testing on Gaming devices and programs that support internal and external progressive functionality. GLI is capable of performing SAS protocol testing on progressive equipment; however, this is very uncommon. Configurable progressive levels are generally set at the site where the game is installed. This can make it impossible to account for every possible value. Therefore, GLI uses the minimum amount guaranteed by the game. This information is disclosed on the certification report. Ticket-in/Ticket-out Testing The ticketing capabilities in Gaming devices are usually tested in accordance with the general ticket testing procedures, any other test scripts applicable the ticket printer, ticket/bill acceptor and the Gaming device in which they are installed. GLI GmbH. Page 16 of 8

17 GLI also performs ticket testing between Kiosks and systems in accordance with the documented procedures. System Testing GLI can also conduct testing between Gaming devices or kiosks and the various slot accounting and slot management systems available. This allows a more precise representation of how a Gaming device and system will perform together as opposed to protocol simulation testing. This includes protocols based on serial, asynchronous, xml, TCP/IP, wireless and other schemas used to handle communication. It also includes testing for Gaming compliance and functionality of systems developed using various combinations of operating platforms, database environments and programming languages. Our engineering team has trained staff members specialized in testing systems used in specific markets. Additionally, being a part of the GLI global network provides our team with access to the resources needed to enable cross training on multiple systems used worldwide. The training, experience, technical and cultural diversity of our European staff members allows GLI to develop and deploy business solutions to meet customer testing requirements tailored to the specific type of system. This helps to facilitate special projects that may involve communication between systems. Engineers are required to travel and work in other GLI locations or in the field as needed to ensure testing projects are handled properly and to improve their testing proficiency. System testing is performed where required by regulations or upon customer request. GLI can accommodate manufacturers to test their items in one of our facilities with the assistance and supervision of an experienced system test engineer. Regulators are also able to use GLI resources and expertise in this field to preview new technology in order to help them understand how it will interface with various systems, including their own central monitoring system. This can help the Regulators to have a better overview on the improvements and benefits associated to the monitoring of the games. The general scope of this testing involves basic connectivity messaging, error/event handling, ticketing (TITO), accounting and other system reports. GLI develops documented test scripts and procedures for system testing that are specific to the applicable system and gaming device involved. Other tasks may be included in this scope of testing. Technical Review Upon the completion of testing, a senior engineer or technical manager performs a review of the completed package to evaluate the quality, accuracy and traceability of the testing. Any discrepancies are documented and returned to the test engineer for correction or clarification. GLI GmbH. Page 17 of 8

18 Report Processing/Quality Assurance Upon completion of testing and technical review, a submission is given to the Quality Assurance department for administrative review and report processing. GLI uses standard Microsoft Office applications for report preparation. The QA staff uses the GLI Database and FORTIS document archival system to perform research during the review of items submitted for processing. The QA Manager or a Documentation Review Specialist assigns the completed test package to a documentation specialist to review the contents for all necessary components prior to reviewing the paperwork quality. The paperwork is then checked for accuracy and completeness prior to drafting the initial report. Engineering staff members are contacted to resolve any questions, discrepancies, issues or missing information. Once all information is verified and all issues are resolved, the report is drafted, checked for accuracy and given to a senior QA staff member to review. Upon completion of the review, the report writer makes all the required changes as advised by the reviewer, then processes and prints all additional reports. Mailing and Updating Finalized reports are given to the submissions group to be mailed. The GLI Submissions Database is updated to reflect the approval status of submissions and all changes are updated on the GLI website within 4 business hours. New approvals are also made available for each jurisdiction on the Internet. All approved software items are catalogued and secured on site. Archive Team members from the scanning department retrieve the updated folders and scan or import the entire contents into our document archival system to create a permanent, unalterable electronic archive of the submission and its corresponding results. GLI GmbH. Page 18 of 8

19 Visual Outline of the GLI Submission Process 1) Submission Receipt ) Submission Review 3) Project Assignment 4) Work Request Joint Quality Assurance and Engineering functions 5) Technical Evaluation 6) Technical Review 7) QA Review 8) Report Prepared 9) Report Reviewed 10) T/I Report and Certification finalized and issued 11) Project Completed and archived GLI GmbH. Page 19 of 8

20 GLI Math Overview Randomness, Probability and Fairness Testing GLI GmbH. has trained engineering staff members to perform and review mathematical testing related to probability and game strategy. They are also required to have their work reviewed by our team of full-time experienced mathematicians, statisticians and programmers at our headquarters location. They assist in projects as needed to evaluate theoretical returns, game volatility analysis and perform other mathematical functions as needed. These tasks are also assigned and tracked using the GLI Submissions database including perform random number generator (RNG) analysis tasks and other similar projects involving the science of mathematics, probability, inferential statistics and some programming. Evaluation of theoretical return and RNG Analysis is briefly described in the following section. GLI augments its testing using mathematicians as needed. When this occurs, thorough review and communication is conducted between all staff involved to ensure proper analysis and implementation of the RNG and Theoretical or absolute RTP as opposed to simply applying a mathematical model to a sampling of data. Evaluation of Theoretical Return to Player (RTP) GLI calculates the return percentage of games by evaluating or simulating every possible combination to determine the theoretical return on investment (ROI or RTP return to player). Mathematicians write programs in C++ and use Microsoft Excel to perform evaluation of pay combinations using the payout table data provided. Simulator programs are written for software with very large quantities of combinations. All of the programs written and spreadsheets containing this information is stored on our network and archived with the technical records. Documented procedures for conducting this type of analysis are contained in our: Math Policy General Math Analysis Procedure Reel Game Math Analysis Procedure Video Poker Math Analysis Procedure Flush Fever Poker Analysis Procedure Odds of Max Award Analysis Procedure Random Number Generator (RNG) Analysis GLI uses custom software written and validated through the collaborative effort of our inhouse mathematicians and industry consultants. The RNG Test Suite application is used for randomness testing. GLI also uses Microsoft Excel to perform certain calculations, estimations and graphical plotting with the data used during the evaluation. The specific test tasks involved in performing the test procedures described below are stored in controlled document libraries on our Intranet in the RNG Analysis document and may be reviewed on site upon request. GLI generally performs these tests to a 95% confidence level as required by most regulatory standards. GLI GmbH. Page 0 of 8

21 1) The first step to performing the actual RNG testing involves obtaining a sample of RNG data to be used for evaluation. The amount of sample data GLI must obtain is determined by: i. Game parameters. 1. The range of each number that can be drawn. This includes a minimum and maximum.. The number of reels, numbers or prizes that are going to be drawn. ii. Indication that the numbers are drawn with or without replacement. ) After the data sample is obtained, GLI performs the following test methods as randomness indicators: a. Chi Square Test This tests for randomness by verifying the existence of a uniform distribution of values over within the range of sampled data. (See Chi Square Test) b. Serial Correlation Test This test is used to identify predictable or nonrandom patterns between groups of draws or groups of games. An example would be random selection between if there was a predictable outcome each time a patron spins the reels. (See Serial Correlation Test) c. Interplay Correlation Test This test is used to identify predictable or nonrandom patterns between or within a single game play. An example would be random selection between each reel on a 5-reel game. (See Interplay Correlation Test) d. Runs Test This test is used to identify groups of predictable or nonrandom activity. An example would be a predictable mix of wins and losses. (See Runs Test) 3) GLI also verifies that all source code provided is free of extraneous routines which could adversely affect the randomness of the core algorithm. 4) Additionally, we review all design documentation to ensure that the overall game concept and design implementation will not adversely affect overall randomness. 5) Other tests that can be used by GLI as needed are the Duplicates Test, Poisson Distribution Test, Uniform Distribution Test and Goodness-of-Fit Test. GLI GmbH. Page 1 of 8

22 Chi-Square Test If the number of draws for each sample is ten times the range, the expected theoretical occurrence of each number from the range in that sample would be ten. Therefore, we would expect to see the number 01 appear ten times in each number position in each sample. However, provided that the RNG is random, we will not always see that exact number of occurrences. The Chi-Square Test compares the observed number of occurrences of each particular number against its theoretical expectation. High Chisquare values, or data skewed to the right, indicate that the actual occurrences are tending to deviate too much from theoretical. Deviating too much from the theoretical expected number of occurrences implies that at least one of the numbers from the range is not being chosen frequently enough or is being picked too frequently. Low Chi-square test statistics, or data skewed to the left, indicate that the observed occurrences do not deviate enough from the theoretical. Deviating too little from the theoretical implies that the data is too predictable. Therefore, if the number 01 had not been drawn recently, it will most likely be drawn soon. Either of the two scenarios will produce non-random data. The parameters and formula used to calculate the Chi-square test statistics are as follows: Given i = the number of samples, i = the calculated Chi-square test statistic, o = the observed number of occurrences of a number from the range, j = the expected number of occurrences f the number from the range, j n = the range, and i n j 1 o j j o o o j n n n n GLI GmbH. Page of 8

23 Serial Correlation Test The Serial Correlation Test determines whether or not the numbers picked for the current draw in any way determines subsequent plays. We calculate a correlation coefficient r based on pairs of data taken from the same number position on consecutive draws. Values for r range from to -1.00, with 0.00 indicating no correlation between events. r n XY XY nx XX n Y YY Interplay Correlation Test This test determines whether or not there is any relation between two positions of numbers chosen within the same draw. It is essentially the same analysis that is performed in the Serial Correlation Test, but it is performed on pairs of data taken from different number positions within the same draw rather than between draws. Games played without replacement will have a left skew in the Interplay Correlation plot. This skew represents that once a particular number is chosen in a draw, it may not be selected again. If the game is played with replacement, we expect to see a standard bell curve. Runs Test This test determines the median of the data obtained for each draw, for each number position, and counts the numbers of runs of data that are either all above the median or all below the median. Data with too few runs is streaky, sometimes running high and other times low. Data with too many runs tends to alternate highlow-high-low more than expected. The runs count V is normally distributed, with a mean of v and a standard deviation of v.these parameters are converted into Z-scores to be evaluated against a normal distribution to create ranks for plotting. GLI GmbH. Page 3 of 8

24 The parameters and formulas used for this test are as follows: Given N 1 = the sum of numbers above the median, N = the sum of numbers below the median, and V = the total number of observed runs above or below the median v N N N N 1 1 1, v N1N N1N N1 N V and Z N N N N 1 v 1 1 v Other Services On-Site Inspection and Certification GLI conducts on-site inspections and certification of gaming machines and devices, on-line monitoring systems and associated equipment in licensed environments. These inspections vary from: Initial start-up of a licensed premises with new gaming machines and on-line systems Installation or upgrade of an on-line monitoring system On-going oversight inspections of modifications and expansion of properties Consulting Services GLI is often retained in a consultant capacity to assist regulators with the auditing process, drafting of rules and technical standards regarding gaming devices, associated equipment, gambling devices, internal controls, rules of the game, conduct of gaming or any other area assistance is requested. The experience GLI has accumulated in its many years of providing technical compliance consulting services first starts with identifying proper and definitive technical standards that gaming equipment must meet to adhere to public policy and provide protection to the playing public. Technical standards are the baseline for which gaming regulators can enforce rules and regulations to protect and uphold the integrity of gaming in each venue. Training Services GLI firmly believes that for gaming jurisdictions to regulate their respective operations effectively, they must have the most up-to-date information available about gaming devices, computer systems and hardware/software located on casino floors for public play. To assist in that endeavor, GLI offers training both at our offices and in the field. GLI GmbH. Page 4 of 8

25 Day-to-Day Operational Services An important aspect of gaming regulation involves the adoption of Minimum Internal Controls Standards (MICS). The GLI staff includes professionals with regulatory experience developing key operational and procedural controls that will mitigate the risk of losing revenue due to internal theft, cheating or negligence. In addition the MICS help maintain a proper audit trail that enables regulators to verify a licensee s compliance and assure the public of the integrity of the gaming operation. GLI s staff, which includes an attorney with extensive regulatory experience, works with regulators to develop MICS language that fits their statutory scheme and meets their regulatory policy objectives. Drafting IT Solutions GLI will develop IT solutions regarding how to use the local terminal to retrieve trusted data from the remote system and high level functionality requirements in order to set up the remote terminals in the Gaming Control Board premises. After the setting up of the terminals by the Operators, GLI will perform an inspection to determine if the remote terminal were set up according to the high level requirements established. Forensic Evaluation Forensic evaluation services are available to regulatory bodies requesting independent analysis of device malfunctions or questionable game operation within a Gaming facility. This requires the work of a senior engineer or technical expert with demonstrated competence and expertise on the device in question. Engineers performing forensic analysis services will work alongside technical compliance personnel to identify, include or exclude any items of relevance to the investigation and subsequent report. When receiving an item for evaluation, the engineer will perform an initial inspection of any items submitted. The items are verified for authenticity and any memory or data required to reconstruct the device s present condition are extracted and copied into a separate testing environment within our laboratory. The items submitted are also catalogued, photographed and secured. GLI procedures are designed to preserve the integrity of any items submitted to ensure they are returned in the exact condition and operational state they were received. The evaluation procedure involves an investigative review of the facts provided about the malfunction or event. Testing is then conducted in the test environment to determine the cause of the malfunction. Engineers assigned to work on these projects use computer memory (RAM) and source code analysis tools in combination with validated testing procedures and logical troubleshooting steps. Upon completion of the evaluation, a report is prepared and reviewed. The final report of findings and the original items submitted are returned to the submitter. GLI GmbH. Page 5 of 8

26 GLI is the world s leading laboratory with 18 stations worldwide GLI GmbH. Page 6 of 8

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