Oversight and Responsibilities Issues related to human rights are governed at the highest level of the company through oversight by the board’s nominating and governance committee as part of its overall ESG responsibility. Global human trafficking prevention is overseen by our chief compliance officer. Ongoing management and implementation of counter-human-trafficking initiatives is the responsibility of our compliance team and our security and surveillance team, who collaborate closely with law enforcement. Prevention of discrimination and harassment is overseen by our senior vice president of global human resources. Policies • Human Rights Statement • Preventing Discrimination and Harassment Policy • Global Human Trafficking Prevention Policy Targets and Commitments We are firmly committed to protecting fundamental rights and freedoms for all people, without regard for race, color, religion, language, ancestry, age, gender, national origin, sexual orientation, gender identity, gender expression, mental or physical disability, genetic information, or marital or veteran status. We are also strongly committed to fairness and equal opportunity in employment and will not tolerate harassment of or discrimination toward Team Members in any form, including sexual harassment by fellow Team Members, supervisors, managers, officers, directors or anyone who interacts with the company such as vendors, contractors, consultants, agents or guests. We condemn human trafficking in any form, including sex trafficking, forced labor and child labor, in our operations and global supply chain. Strategy Human rights protection is fully integrated into our business, with stringent processes and rigid standards to enforce our zero-tolerance policy for violations. We proactively identify risks associated with our salient human rights issues and seek to prevent and mitigate adverse impacts in our direct operations and value chain. Significant risks are escalated, managed and reported to the board through our enterprise risk management (ERM) process. We require suppliers to provide fair and safe working conditions and treat their employees with dignity and respect. As part of our supply chain management process, we mitigate and address adverse human rights impacts, including child labor, forced labor, human trafficking, remuneration, discrimination, harassment, freedom of association and collective bargaining. We also screen for human rights risks when establishing new business relationships and ventures. Discrimination and Harassment: To mitigate risk, we conduct background checks before hiring, and all Team Members must agree to our Code of Business Conduct and Ethics and attend annual training. When issues arise, our remediation process includes conducting prompt, consistent, thorough and neutral investigations by our human resources, compliance, investigations and legal teams, as well as other departments that may be impacted. Human Trafficking: We have instituted proactive and reactive strategies through Sands Project Protect to safeguard our properties and patrons from human trafficking. Additional measures are in place to prevent trafficking associated with personnel such as construction and migrant workers. Training and Communications All Team Members must acknowledge our Code of Business Conduct and Ethics and participate in mandatory anti-harassment and nondiscrimination training upon hiring and annually. Certain team members are required to take a separate manager level training. We encourage Team Members to report incidents to human resources or through our confidential third-party ethics hotline, which is reinforced by a nonretaliation policy. All Team Members are trained to identify suspicious activity with respect to human trafficking, and front‑line Team Members receive additional training. Team Members and guests have several means to report suspected incidents, including alerting security or management personnel, contacting the company through corporate and property websites, and using our anonymous ethics hotline, which is available in multiple languages. Evaluation and Adjustments We update our processes and protocols for addressing human rights risks on an ongoing basis to incorporate the latest intelligence and standards of performance. To maintain a pulse on the current environment, we review and establish metrics for discrimination and harassment cases in our risk assessment. Team Members are also asked to participate in periodic pulse surveys. MANAGEMENT APPROACH HUMAN R I GHTS 2022 ESG REPORT 76
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