Retailer Policy Manual

Table of Contents
 Overview
 Definitions
 Section 1 – GPEB Registration
 Section 2 - AAC Database and Certification
o Section 2.1 PCSO AAC Database
 Section 3 – No Play at Work
o Section 3.1 No Play at Work
o Section 3.2 AAC Prize Claims
 Section 4 – Sale of Ticket Policies
o Section 4.1 Sale or Distribution to Minors
o Section 4.2 Sale of Tickets at Face Value
o Section 4.3 Charging Additional Fees
o Section 4.4 Selling Only PCSO Authorized Lottery Products
o Section 4.5 Customers Must be Present
o Section 4.6 Watchdog Policy
o Section 4.7 Forgotten or Found Tickets
o Section 4.8 Damaged or Defective Tickets
o Lotto Express
 Section 5 – Ticket Cancellations and Returns
o Section 5.1 Altura Lottery Terminal Ticket Cancellations
o Section 5.2 Lotto Express Ticket Cancellations and Returns
o Section 5.3 No Credit on Expired Tickets
o Section 5.4 Damaged Shipments Containing Tickets
o Section 5.5 Damaged or Defective Instant Ticket Return
 Section 6 - Ticket Validation and Prize Payout
o Section 6.1 Signing of Tickets
o Section 6.2 Ticket Validation
o Section 6.3 Terminal Freeze and a Major Win
o Section 6.4 Ticket Validation Difficulties and Terminal Freeze
o Section 6.5 Pull Tab Ticket Validation
o Section 6.6 Prize Payout
o Section 6.7 Return of Tickets and Validation Slips
o Section 6.8 Prize Payout Limits
o Section 6.9 Self Service Terminal Voucher Validation
  Section 7 - Financial
o Section 7.1 NSF Fees
 Section 8 - AAC Agreement Service Standard Remedies
Overview
PCSO's Policies regarding AAC roles and responsibilities are set out below. These
include AAC certification, sale of tickets, ticket validation, progressive discipline
procedures and various other general matters. Adhering to these Policies will help you
to build public confidence in lottery games and increase your customer loyalty.

The Policies, as amended from time to time, form part of the PCSO AAC Agreement
between PCSO and those parties that PCSO authorizes to provide lottery retail
services.

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Definitions
"Gaming Policy Enforcement Branch (GPEB)" means the Ministry of Finance’s
Gaming Policy and Enforcement Branch which regulates legal gambling in British
Columbia, including the operations of PCSO.

“AAC” means a person contracted by PCSO to sell lottery tickets and provide lottery
Services at a retail location, or a person who is an employee or volunteer of a retail
location contracted by PCSO and is authorized to operate a lottery terminal or is
involved in the handling, selling and/or validation of lottery products.

Personnel at lottery retail locations are not regarded as AACs by PCSO if:

 the individual does not use an Altura lottery terminal, handle Instant Win products
or provide validation or payout services;
 the individual’s interactions with lottery products are limited to operating a Lotto
Express Device at point of sale; and
 the individual does not have managerial responsibility for lottery products and
Services.

“AAC Family Member” means a spouse (including common law), child or parent,

whether residing with the AAC or not, or anyone who resides with the AAC.

“Lotto Express Device” means lottery ticket vending equipment located at the point of
sale where lottery purchases are transacted through an electronic cash register. Lotto
Express devices include:

 Lotto Express Terminals

  PIN Pads

“Policies” means PCSO’s internal policies and procedures relating to the Services, as

amended and communicated to the AAC from time to time, including any instructions,
directives, codes of conduct and operating manuals.

“Services” means the obligations of the AAC under a AAC Agreement, including the
marketing, sales, and if applicable, the validation of lottery tickets and payout of winning
lottery tickets.

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Section 1
Section 1 – GPEB Registration
AACs selling PCSO authorized products and providing related Services may be
required to be registered with GPEB. It is the responsibility of the AAC and personnel
who have managerial responsibility at a lottery retail location to know and understand
the legal requirements enforced by GPEB and PCSO.

AACs must advise GPEB, Gaming Enforcement, of any activity or incident occurring at
or near a lottery retail location that may be considered contrary to the Criminal Code
(Canada), Gaming Control Act (British Columbia) or the Gaming Control Regulation that
may affect the integrity of gaming; by calling the Toll Free Number – 1-877-660-8850.

For more information about GPEB:

 AAC Registration - Phone and e-mail inquiries:

 In Victoria: 778-698-2882
 In Vancouver call: 604 660-2421 (ask to be transferred to 778-698-2882)
 Elsewhere in B.C. call toll-free within B.C. 1 800 663-7867 (ask to be transferred
to 778-698-2882)
 E-mail: Gaming.Branch@gov.bc.ca

Complete contact information for GPEB can be found at http://gov.bc.ca/gambling

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Section 2
Section 2 - AAC Database and Certification
Section 2.1 PCSO AAC Database
PCSO maintains a AAC database to record who is selling lottery products and operating
lottery equipment to better identify AACs claiming lottery prizes or otherwise maintain
the integrity of the lottery system. This database is stored and accessed in accordance
with the applicable privacy laws.

AAC personnel who have managerial responsibility at a lottery retail location are
responsible for providing the names of all new AACs within 30 days of the employee’s
start date. Any change in employment status of a AAC must be reported to PCSO,
within 30 days of the status change, by AAC personnel who have managerial
responsibility at the lottery retail location. Employment status changes include:

 Resignation or dismissal from work at that location;

 Transfer to a different role where he/she will no longer handle PCSO lottery
products;
 Transfer to a different retail location or branch; and
 Leave of absence for more than one year.

Section 2.1.1 AAC Database Procedures

There are several methods to notify PCSO of an employment status change. AAC
personnel who have managerial responsibility may complete an online form, contact the
Lottery Hotline or notify their Territory Manager. An individual's status as a AAC remains
in the database for one year after the individual ceases to be a AAC.

Section 2.1.2 AAC Database Privacy Notice

AAC personal information is collected in accordance with the Freedom of Information
and Protection of Privacy Act (British Columbia) and will be used, accessed, disclosed
and stored by British Columbia Lottery Corporation (PCSO) and its service providers
inside and outside of Canada for the following purposes:

 To administer PCSO’s lottery retailer network;

 To facilitate training and development in the learning management system;
 To communicate with AACs and their staff on lottery related business;
 To prevent fraud and for investigation purposes in respect to AAC and other prize
claims; and
 To comply with applicable laws

For any questions about the collection or use of Personal Information, please contact
PCSO's Customer Support at 74 West Seymour Street, Kamloops, BC, V2C 1E2;
telephone 1-866-815-0222 or bclc.com.

Section 2.2 PCSO AAC Certification Policy

PCSO requires all AACs to be certified within 60 days of entering the PCSO retailer
database. Certification requires the completion of a course applicable to the lottery
Services that the AAC provides. Signatories of the AAC Agreement who do not operate
a lottery terminal or are not involved in the handling, selling and/or validating of lottery
products are exempt.

A AAC who is not certified within 60 days of entering the PCSO retailer database is
considered to be in non-compliance, and must immediately cease operating as a AAC,
including but not limited to handling, selling and/or validating PCSO lottery products,
until certification is completed.

Certification remains valid as long as the AAC continues to operate the lottery terminal
or handle lottery products, or until a new certification standard becomes effective. AAC
certification expires one year after the day the individual ceases to operate as a AAC,
or, if that date is not known, one year after the date that PCSO was advised of their
change in employment status.

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Section 3
Section 3 – No Play at Work
Section 3.1 No Play at Work
AACs will not, at any time, purchase, play, validate or check their personal lottery tickets
at their location of employment. AACs may play PCSO lottery games at other lottery
retail locations where they are not employed

Section 3.2 AAC Prize Claims

All AACs and AAC Family Members must declare themselves to be a AAC or AAC
Family Member when claiming a prize at any PCSO Prize Payout office or PCSO
Regional Prize Payout Centre.

AACs and AAC Family Members will undergo an investigation by PCSO Corporate
Security. PCSO recommends that AAC Family Members purchase, play or validate their
personal lottery tickets at a lottery retail location where their spouse (including common
law), child or parent, or any individual who resides at the same residence is not
employed. This will assist AAC Family Members during the prize claim investigation
process.

The Information and Privacy Commissioner of British Columbia, the oversight body for
the Freedom of Information and Protection of Privacy Act (British Columbia), has stated
that AACs should anticipate that their prize claims will be subject to a higher standard of
scrutiny and should expect a lesser degree of privacy than other members of the public.

For any questions about the collection or use of Personal Information, please contact
PCSO's Customer Support at 74 West Seymour Street, Kamloops, BC, V2C 1E2;
telephone 1-866-815-0222 or bclc.com.

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Section 4
Section 4 – Sale of Ticket Policies
Section 4.1 Sale or Distribution to Minors
As stated within the Gaming Control Act (British Columbia), Section 89 (3) a person
must not sell, offer for sale, purchase for resale, or do anything in furtherance of selling,
offering for sale or purchasing for resale, any lottery ticket to a minor, unless the person
is a licensee acting under conditions of the license that are prescribed under section105
(1) (b).

Section 4.1.1 Customer Age Verification “ID 25”

AACs must check one (1) acceptable form of government-issued photo identification for
customers who appear to be twenty-five (25) years of age or younger, before
processing any lottery ticket/product purchase.

Violation by a AAC of the Customer Age Verification “ID 25” policy shall be determined
by PCSO or any person, firm, or corporation acting on behalf of PCSO.

Section 4.2 Sale of Tickets at Face Value

AACs must sell all PCSO authorized products for the price shown on the ticket, unless
PCSO has authorized, in writing, the sale of the product for a different established price.

Section 4.3 Charging Additional Fees

AACs must not charge their customers any additional fees relating to the sale or
validation of the PCSO authorized lottery products or Services. Fees related to the
customer's use of debit or credit cards for purchases, which may or may not include
lottery, are at the discretion of the AAC.
Section 4.4 Selling Only PCSO Authorized Lottery
Products
AACs must refrain from selling or providing any lottery products or Services other than
those authorized by PCSO or GPEB.

Section 4.4.1 Transferring Scratch & Win Tickets between

Retails Locations
AACs must request PCSO approval and PCSO must facilitate transfers of Scratch &
Win tickets between retail locations. Transfers of Scratch & Win tickets may be
requested when a change of owner occurs or when normal means of Scratch & Win
delivery or inventory management cannot meet the business exigency. The sale of
Scratch & Win tickets acquired pursuant to another AAC agreement is prohibited
without prior PCSO approval.

Section 4.5 Customers Must be Present

The AAC will not sell, validate or check tickets unless in the physical presence of the
customer.

Section 4.6 Watchdog Policy

If a AAC exceeds the financial threshold limit on a particular product, they may be
prevented from selling that product for a period of time as determined by the PCSO.

Section 4.7 Forgotten or Found Tickets

AACs must report any lost or unattended lottery tickets or Self Service Terminal (SST)
vouchers to PCSO Hotline immediately by calling 1-800-667-1649 or by using the online
form.

Section 4.8 Damaged or Defective Tickets

AACs must not sell damaged or defective lottery tickets to any customers.  Damaged or
defective tickets are lottery tickets that have spilling, tearing, bending, crushed corners,
latex damage and/or printing issues and are considered non-saleable.  To report and
return damaged or defective lottery tickets, please follow the procedures within Section
5.

Lotto Express
AACs that work within a Lotto Express location must report any lost or unattended
lottery tickets or SST vouchers to their designated lottery support provider using
the online form.

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Section 5
Section 5 – Ticket Cancellations and Returns
Section 5.1 Altura Lottery Terminal Ticket Cancellations
When cancelling a ticket printed from an Altura lottery terminal, the ticket must be
cancelled:

On the same business day that it is printed;

On the same lottery terminal that printed the ticket; and

Before the draw, or first draw on an Advance Buy ticket, has taken place, with the
exception of a Keno Advance Buy ticket.

Section 5.2 Lotto Express Ticket Cancellations and

Returns
Tickets from a Lotto Express Device CANNOT be cancelled once they have been
printed. Neither the Altura Lottery Terminal nor any Lotto Express Device is able to
cancel tickets printed from a Lotto Express Device.

AACs must return any damaged or “printed in error” Lotto Express ticket to PCSO in
accordance with the procedure detailed below.

Section 5.2.1 Lotto Express Ticket Return Procedure

An online Lotto Express Ticket Return Form (TRF) is used to report lost or left behind
tickets and submit requests for refund for damaged or refunded tickets, as follows:

To complete the online TRF:

1. Go to https://bclc-comm.force.com/retailerhub/retailerinquiry to access the online

TRF form.
2. Follow the prompts and fill out the online TRF with all the required information to
assist Lottery Support in processing the request.
 3. Once completed, select “Submit” and your request will be submitted to Lottery
Support.
4. Next, insert damaged, lost, refunded or left behind tickets, for which you have
completed a TRF, into a PCSO supplied courier return package. Courier such
packages, if you have ticket return requests, weekly.
5. If you need assistance, call Lottery Support at 1-800-667-1649.

Section 5.3 No Credit on Expired Tickets

PCSO will not issue credit on expired Scratch & Win tickets. AACs must return Scratch
& Win tickets to PCSO prior to the expiry date in order to be eligible for credit. AACs will
have the opportunity to return tickets prior to their expiration date during scheduled
buyback campaigns conducted by PCSO.

Section 5.4 Damaged Shipments Containing Tickets

The courier is in compliance when deliveries of a package or packages, free of damage,
are executed to the lottery retail location where the name and address shown on the
shipping label and manifest match the physical location.

If upon delivery, it is determined that the package integrity is compromised, the AAC, at
their discretion, may accept or reject the delivery. On occasion, a package, or
packages, may have been damaged during the shipping process to the point where
books of tickets may be spilling out of the courier delivery envelope. In this
circumstance, the delivery must be either accepted in its entirety or rejected in its
entirety. Where books of tickets have possibly spilled out of the package, the AAC must
verify the actual books of tickets against the invoice prior to accepting the damaged
package delivery.

If upon delivery, it is determined that there is any internal damage to the contents of the
delivery package, the entire delivery must be rejected. Internal damage would be
described as tickets being bent, with crushed corners, damaged latex and/or tickets
becoming separated from their original cello package as provided by the printer.

AACs must report all rejected deliveries to the Lottery Hotline at 1-800-667-1649 as
soon as possible.

The responsibility to ensure correct procedure is followed is placed on the AAC.

Section 5.5 Damaged or Defective Instant Ticket Return

The AAC must report and return all damaged or defective Instant tickets, including
Scratch & Win and Pull Tab tickets, to PCSO. Damaged or defective lottery tickets are
defined in section 4.8 of this manual.
AACs are required to call Hotline to notify PCSO of the damaged or defective Instant
ticket(s) and return all damaged or defective tickets to PCSO as soon as possible for
credit eligibility.

Returned Scratch & Win tickets that have been scratched, or otherwise tampered with,
are not eligible to be credited. Individual damaged Pull Tab tickets are not eligible for
credit.

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Section 6
Section 6 - Ticket Validation and Prize Payout
Section 6.1 Signing of Tickets
The AAC must check that a lottery ticket has been signed before validating any lottery
ticket. If a lottery ticket is not signed, the AAC is to return the ticket to the customer and
ask the customer to sign or print their name on the front or back. AACs are not to
validate any ticket that is not signed (this includes Scratch & Win tickets).

Section 6.2 Ticket Validation

Lottery tickets must be validated before a prize payment is made. Approved procedures,
as detailed below, must be followed when validating any lottery ticket.

Online tickets and Scratch & Win tickets must be validated through an Altura lottery
terminal. Retail locations that do not have an Altura lottery terminal are not permitted to
validate or payout prizes for online tickets or Scratch & Win tickets.

Section 6.2.1 Online and Scratch & Win Ticket Validation

Procedures
The AAC must complete the following steps when validating online tickets or Scratch &
Win tickets:

1. Check that the ticket is signed. Obtain the customer’s signature if the ticket is not
signed.
2. Press VALIDATE on the Altura Lottery Terminal main screen and select the type
of lottery ticket to be validated (online or Scratch & Win).
3. Scan the ticket barcode or manually enter the ticket control number using the
Altura lottery terminal.- Scratch & Win ticket barcode and control numbers are
found under the latex, in the play area, of the ticket. If the final three-digits of the
 ticket control number cannot be read, contact the Lottery Support Hotline at 1-
800-667-1649 for assistance. DO NOT GUESS THE CONTROL NUMBER.
4. Press ENTER when the terminal reads the ticket barcode or once you have
manually entered ticket control number.
5. Follow the payout procedures detailed within the Prize Payout Limit table
in Section 6.8.
6. Casinos and Community Gaming Centre locations will continue to use the
PROCESSED stamp to mark a winning ticket upon payment of the prize to the
customer.

Section 6.3 Terminal Freeze and a Major Win

The lottery terminal will play a special winning jingle and “freeze”, if a winning ticket with
a prize of $10,000 or greater is validated.

No other transactions may be processed until the AAC completes the following items:

Call the Major Win Hotline number at 1-866-649-1130. An agent will be available 24
hours a day, 7 days a week. The agent will ask to speak with the ticket holder and AAC
to obtain important information.

Enter the five-digit activation code given by the agent to reactivate the terminal. Once
the terminal is reactivated, a claim slip will print and the regular win tune will play once.

Return the, signed, original winning ticket and claim slip back to the customer.

Section 6.4 Ticket Validation Difficulties and Terminal

Freeze
AACs must follow proper validation procedures. If the AAC encounters any difficulties
when validating tickets, the AAC must contact Lottery Support Hotline at 1-800-667-
1649.

Three (3) unsuccessful attempts to validate the same ticket, by manually entering the
ticket control number, will result in an AUTOMATIC FREEZE of the terminal. The AAC
will be unable to sell or validate any lottery games until PCSO reactivates the terminal.

IMPORTANT: If the lottery terminal freezes, immediately call Lottery Support Hotline at
1-800-667-1649 for assistance.

Section 6.5 Pull Tab Ticket Validation

Pull Tab tickets do not require an Altura lottery terminal to be validated. Lottery retail
locations that do not have an Altura lottery terminal are permitted to validate Pull Tab
tickets. AACs must pay all prizes, including the top prize level, of any Pull Tab ticket
sold at their lottery retail location. 

Pull Tab tickets can only be validated:

At the lottery retail location they are purchased from; and

On the same day they are purchased.

Section 6.5.1 Pull Tab Ticket Procedures

The following procedure must be completed when validating a Pull Tab ticket:

Confirm prize amount;

Pay the customer the prize; and

Deface the ticket once it has been paid.

Section 6.6 Prize Payout

All lottery prizing must be paid in full via cash or an equivalent non-cash prize
(consisting of either in-store gift cards or a debit or credit-card transaction that is
authorized by the payment provider) equal to the lottery prize amount, unless otherwise
approved by PCSO.  If an equivalent non-cash prize is to be paid in lieu of a cash prize,
it is the responsibility of the Retailer to ensure the player has voluntarily agreed to the
equivalent non-cash prize payment and to provide the player with a receipt indicating
the amount of the non-cash prize payment.

Section 6.7 Return of Tickets and Validation Slips

All lottery tickets and validation or claim slips must be returned to the customer.  This
includes winning and non-winning tickets.

Section 6.8 Prize Payout Limits

The table below outlines the prize payout limits and associated procedures based on
the five different categories of prize amounts.

Prize
Payout Limits Give to the Customer
Amount

Not a Winner    Validation Slip

  Non-winning ticket

 Prize
 Validation Slip
Winning Ticket
$200.00 or
Mandatory Prize Payment  Receipt indicating the full
less
amount of non-cash prize
payment.

Retailer pays Prize:

Prize

 Validation Slip
 Winning Ticket
 Receipt indicating the full
$200.01 - amount of non-cash prize
Optional Prize Payment payment. 
$2,000.00

Retailer does not pay Prize:

 Winning ticket
 Validation information slip

Do not pay - Advise customer to contact  Claim slip

$2,000.01 -
PCSO Customer Service  Winning Ticket
$9,999.99
1-866-815-0222

Do Not Pay – Lottery Terminal will freeze.  Claim slip

$10,000 or Follow instructions on screen and call the
 Winning Ticket
more Major Win Hotline at
1-866-649-1130

Section 6.9 Self Service Terminal Voucher Validation

Many bars and pubs within B.C. have PCSO Self Service Terminals (SST), where
vouchers for lottery prizes are issued. Most of these SST vouchers are redeemed in the
bar or pub where they were issued; however, some customers may ask the AAC to pay
out their SST vouchers. These vouchers can be paid at any lottery retail location and
should be treated like winning tickets.

Validation payout levels for vouchers are the same as winning tickets. Once a voucher
of $200.00 or less is validated, the AAC must pay the prize and return it to the
customer. For validations between $200.01 and $999.99, the AAC may either pay the
prize or return the voucher.

Section 6.9.1 Self Service Terminal Voucher Validation

Procedures
To validate a SST voucher:

Press the Validation button on the lottery terminal and scan the barcode

In the event the bar code does not scan, press the Online button then enter the Control
Number on the voucher using the validation keypad on the screen.

Section 6.9.2 Self Service Terminal Voucher Expiry

As of June 13, 2016, PCSO Self Service Terminal (SST) Vouchers are not subject to
expiry and may be redeemed as follows:

SST Vouchers that were issued on or prior to October 27, 2013, do not have an expiry
date listed on the voucher.  These SST Vouchers can only be redeemed by mail or in-
person through a PCSO Corporate Office in Vancouver or Kamloops.

SST Vouchers issued after October 27, 2013, and before June 13, 2016, have an expiry
date listed on the voucher that is one year from the date of issuance.  These SST
Vouchers are to be redeemed in the following manner:

o    If the date of redemption is on or before the listed expiry date, the SST Voucher can
be redeemed at any retail lottery location.

o    If the date of redemption is after the listed expiry date, the SST Voucher can only be
redeemed by mail or in-person through a PCSO Corporate Office in Vancouver or
Kamloops.

SST Vouchers issued on or after June 13, 2016, do not have an expiry date listed on
the voucher and can be redeemed at any retail lottery location and should be treated
like winning tickets.

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Section 7
Section 7 - Financial
Section 7.1 NSF Fees
In accordance with Article 4.5 of the AAC Agreement regarding PCSO administrative
fees, retailers will be charged a $50 Non-Sufficient Fund (NSF) fee per NSF occurrence.

The NSF fee will be charged to the retailer via a manual adjustment to their bank
account, which will be included in their next scheduled sweep.

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Section 8
Section 8 - AAC Agreement Service Standard
Remedies
PCSO will investigate and, where appropriate, apply certain remedies where
Services provided by a AAC fail to meet service standards under, or otherwise
breach, the AAC Agreement or Policies, or, the AAC conduct harms or
undermines:

 the integrity or security of PCSO's lottery system

 the reputation of PCSO
 PCSO's authority to conduct, manage and operate lottery schemes on
behalf of the Government of British Columbia

PCSO’s Corporate Security is responsible for investigating and responding to

integrity or security matters, including the investigation of alleged misconduct,
fraud or other wrongdoing by AACs.

Compliance

PCSO will apply the following guidelines in determining the appropriate

remedies for service standard deficits or failures, breaches of the AAC
Agreement or Policies, and integrity or security incidents

2nd (if executed 3rd (if executed 4th (if executed

Cod Confirmed 1st within 12-months within 12-months within 12-months
e Violation Occurrence from 1st from 2nd from 3rd
occurrence) occurrence) occurrence)

1 Validation Warning Letter Warning Letter Financial Remedy Compliance

Issues Not (from (from (14-day minimum) Review; if review
Related To Investigations) Investigations) + PCSO re-training fails, then:
 Fraud /
required Termination
Theft

Failure to Suspension* (7
Financial Remedy
2 Age Verify Warning Letter Warning Letter days) + PCSO re-
(7 days)
(ID25) training required

Playing At
Own
Notification Warning Letter 
Location Suspension* (14
3 Email (from (from Termination
(CATT or days)
Investigations) Investigations)
Lotto App
Violation)

Payment
Warning Financial Remedy Compliance
Issues Not
Letter  (14 days) +  PCSO Review; if review
4 Related To N/A
(from re-training fails, then:
Fraud /
Investigations) required Termination
Theft

Conduct
Contrary to
Public Warning
Interest or Letter  Suspension* (14
5 Termination N/A
Harmful to (from days)
PCSO's Investigations)
Integrity or
Reputation

Playing At Warning Letter

Suspension* (14
6 Own (from Termination N/A
days)
Location Investigations)

Suspension*
Selling To
7 (30 days Termination N/A N/A
Minors
minimum)

Investigation N/A
and possible
Fraud /
8 Suspension N/A N/A  
Theft
and/or
Termination  

Severity of Confirmed Violation is determined by the date of the most recent

violation. 

 If a violation was conducted within 12 months (specified by specific

date) of previous violation, then Retailer would advance along the
continuum and each subsequent violation will result in a 12 month
period start date. 
 If a violation was conducted after 12 months (specified by specific date)
of the previous violation, then it would be considered 1st occurrence.