Oversight and Responsibilities Each region’s director of responsible gaming oversees and implements our responsible gaming programs and is assisted by Responsible Gaming Ambassadors and casino Team Members who have been trained on identifying signs of problem gaming behavior. In addition, all Team Members undergo periodic training on these topics and are responsible for following processes and providing support. Our compliance department is responsible for managing conformity with our global anti-money laundering policy. For more information, please see our management approach for ethical conduct on page 86 of the Appendix. Policies • Responsible Gaming Program • Global Anti-Money Laundering Policy Targets and Commitments We are committed to establishing an environment that promotes responsible gaming by raising awareness of the potential effects of problem gambling behaviors and providing information for patrons seeking help. Our properties adhere to local laws addressing casino operations, advertising and marketing, which are heavily regulated in all jurisdictions, and support social safeguards established by local governments. In addition, Sands is committed to the American Gaming Association’s (AGA) Responsible Gaming Code of Conduct, which includes provisions for employee assistance and training, alcohol service, casino games, and advertising and marketing of casino gambling. Every three years, Marina Bay Sands undergoes assessment through the Responsible Gambling Council’s RG Check standards, a comprehensive and rigorous responsible gambling accreditation program. The property’s accreditation was renewed in 2020. The Venetian Macao and The Londoner Macao obtained accreditation for Macao’s Responsible Gaming Indicators in 2022. As part of our commitment to the AGA’s Responsible Gaming Code of Conduct, advertising and marketing of casino gaming strictly complies with all state and federal standards. We make no false or misleading claims and do not exaggerate claims about the probabilities of winning or losing at various games. In addition, our advertising and marketing materials contain responsible gaming messages, which may include toll-free helplines, and are not placed before vulnerable audiences, including problem gamblers and where most of the audience is expected to be below the legal age to participate. In Singapore, regulations include obtaining preapproval of casino advertisements and promotional materials from the Ministry of Social and Family Development. Sands is committed to complying with all applicable anti-money laundering laws, regulations and policies in our global regions. The countries where we operate have implemented laws that require reporting of certain transactions and suspicious behaviors to help safeguard the financial system and other covered businesses from illicit use, and to detect and report dealings that may be indicative of underlying criminal or terrorist activity. Sands proactively enforces industry-leading anti-money laundering policies and procedures that meet or exceed government regulations in five key areas: customer screenings and due diligence, transactional controls, employee training, reporting and recordkeeping. All physical and electronic records, including anti-money laundering records, are retained for no less than the period required by law, which is currently five years. Strategy Responsible Gaming: Our strategy includes five core pillars: Team Member training, self-limit options, accessible and prominent signage for resources, partnerships with organizations that address the issue and a unique Responsible Gaming Ambassador program that was developed with leading experts and stations Team Member support on casino floors 24 hours per day, seven days per week. We employ standard industry protocols, such as prominent posting of problem gambling helplines, throughout our properties. Safeguards: We maintain customer due diligence guidelines and controls that are risk-based for high-volume credit and cash patrons, which include collection, validation and analysis of basic identity and source of funds information and name-matching against lists of known parties, such as politically exposed persons, among other procedures. Executive approval processes for politically exposed persons are maintained at the local level, with exceptions approved by the global chief compliance officer. Training and Communications All Team Members participate in annual, comprehensive responsible gaming training to learn how to recognize the signs of potential gaming-related problems and bring concerns to a Responsible Gaming Ambassador, who has gone through intensive training led by university and gaming industry experts. Team Members working in relevant areas are targeted for specific training related to anti-money laundering, beyond the annual compliance training provided to all Team Members. Evaluation and Adjustments Our responsible gaming program is evaluated regularly for alignment with leading industry research and science-driven best practices. We optimize our programs through ongoing partnerships with industry experts, problem gaming prevention and treatment centers, and educational and community organizations specializing in this area. Our properties participate in annual independent, risk-based testing of their compliance with our anti-money laundering program and policies as well as local laws and regulations. MANAGEMENT APPROACH RESPONS I BLE GAM I NG AND F I NANC I AL CR I MES PREVENT I ON 2022 ESG REPORT 78
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