Anti-Corruption and Anti-Bribery Policy

“Resorts World” or “Company” has strict policies to prevent and detect anti-corruption and anti-bribery by its employees or with third parties.

Resorts World aims for honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, compliance with applicable governmental laws, rules and regulations, and the prompt reporting to the appropriate persons of potential conflicts of interest.

Resorts World has established standards for behavior that affect the Company; and employees, officers and directors should comply with those standards. The Company promotes ethical behavior and encourages employees to talk to supervisors, managers, or other appropriate personnel when in doubt about the best course of action in a particular situation. If you are aware of a situation that you believe may violate or lead to a violation of any Company policy, please follow the guidelines below.

It is not possible to define the proper conduct and ethical behavior for every situation that may arise. However, Resorts World believes in honesty and integrity at all times in all transactions. Specific policies concerning certain aspects of ethical business conduct are discussed below, but the following are not in any way meant to be a complete code of business conduct and ethics.

  1. Anti-Bribery & Anti-Corruption Policy (ABAC)

Resorts World is committed to conduct its business in an ethical and upstanding manner. The Company and their employees are required to observe and adhere strictly to the following Anti-Bribery & Anti-Corruption Policy:

(A) General Policy:

  1. Resorts World is committed to observing the laws and regulations which govern the countries in which the Company operates.
    2. Resorts World practices “ZERO-TOLERANCE” to acts of bribery and corruption, either directly or indirectly, by persons associated with the Resorts World; including:
  • 2.1 The Company’s employees (the “Employees”); and
  • 2.2 Agents, consultants, representatives, distributors, contractors, suppliers, joint venture partners and any other person(s) associated with the Group (collectively “Business Associates”).

(B) Action by Company:

  1. To put in place suitable and appropriate channels of communications to ensure that:
  • 1.1 Employees and Business Associates are given access to report any suspicions acts or incidents of bribery and/or corruption that they may be aware of without fear;
  • 1.2 Sensitive information pertaining to incidents and acts of bribery and corruption is handled properly and appropriately.
  • 1.3 Employees are not at any time penalized for any loss of business to the Company
    which is a result of (whether directly or indirectly) the Employees’ adherence to the
    Anti-Bribery & Anti-Corruption Program (the “ABAC Program”).
  1. The Company does:
  • 2.1 Take stern and immediate action against any Employee and/or Business Associate who is proven to be or have been involved in acts of bribery and/or corruption;
  • 2.2 Avoid having any business transaction with any party who does not accept the principles of the ABAC Program;
  • 2.3 Review and improve the ABAC Program periodically;
  • 2.4 Not take any adverse action against Employees or Business Associates for bringing to the attention of the Group (in good faith) a known or suspected breach of this ABAC Program.

(C) Action by Employees:

All Employees are expected to:

  1. Carry out the Company’s business dealings and transactions fairly, professionally, ethically, honestly and with integrity.
    2. Report any suspicious, acts or incidents of bribery and/or corruption that they may be aware of.
    3. Not at any time or in any manner, make bribes in order to retain, secure or obtain any commercial, contractual, personal or business advantage.
    4. Not at any time or in any manner, accept bribes or unofficial payments.
    5. Not permit any third party to accept bribes or unofficial payments on his behalf.

An Employee’s failure to comply with this policy may lead to discipline up to and including termination; and if appropriate, Resorts World will pursue all available legal remedies.

Regulatory Compliance
The Company operates in a highly regulated environment. The agencies that regulate its business include the New York State Gaming Commission, Sullivan County Liquor and Gaming Licensing Board, plus many other federal, state and local agencies. The Company and its employees must comply with the regulatory requirements of these agencies. Employees should take an active role by being knowledgeable about all applicable laws and regulations, attending trainings and requesting information. Employees are required to promptly report regulatory violations, or suspected regulatory violations to a supervisor or the Legal Department.

Compliance and Reporting
Strict compliance with these policies is required. In addition, employees are required to promptly report any violation of these policies which they observe or of which they have knowledge to the Director of Human Resources or the Legal Department. Employees who do not comply with these policies, or who fail to report violations of this policy, are subject to immediate disciplinary action, up to and including dismissal. Willful disregard of criminal statutes underlying this Policy may require the Company to refer such violation for criminal prosecution or civil action.
In addition to the reporting procedures set forth above, reporting of issues related to this policy may be made by employees anonymously through the Company’s reporting hotline by calling 1-833-964-0232, which is coordinated by an independent executive.

All conversations, calls, and reports made under this policy are taken seriously. Any allegations that are knowingly false or without a reasonable belief in the truth and accuracy of such information will be viewed as a serious disciplinary offense.