Oversight and Responsibilities The board of directors’ compliance and operational compliance committees ensure Sands’ Code of Business Conduct and Ethics is properly implemented and administered by providing oversight to compliance departments at the global and regional levels. Responsibility for implementation of policies and procedures established under the Code of Business Conduct and Ethics is provided by the company’s chief compliance officer, who is supported by our corporate compliance committee, which includes relevant corporate and regional operating groups’ executives. All Team Members are responsible for following the Code of Business Conduct and Ethics and reporting any violations or concerns in accordance with the company’s Reporting and Non-Retaliation Policy. Managers and supervisors are responsible for maintaining a work environment in which constructive, candid and open discussion is encouraged and expected, without fear of retaliation. Policies • Code of Business Conduct and Ethics • Reporting and Non-Retaliation Policy • Securities Trading Policy • Anti-Corruption Policy • Anti-Money Laundering Policy • Politically Exposed Persons Policy • Corporate Giving Guidelines • Tax Overview Targets and Commitments We are committed to our core values of excellence in business performance, impeccable service, innovation, sustainability, and fairness and honesty in all that we do. We act ethically not only to protect our company, but because it is the right thing to do for our stakeholders and society as a whole. Our commitment to ethics includes maintaining the highest standards of professional conduct in every activity and wherever we conduct business. We take ethical concerns extremely seriously and do not accept misconduct by senior managers, Team Members, suppliers, contractors or other agents. Company policy prohibits retaliation, harassment and intimidation against anyone who reports suspected misconduct or participates in the investigation of issues. Strategy We follow the letter and the spirit of all laws and regulations that govern the company’s conduct. We are aware of our global obligations and act with integrity in every action we take on behalf of the company. Our Code of Business Conduct and Ethics provides a high-level overview of the core principles that govern our way of doing business and helps us detect and prevent violations of law and corporate policy while promoting individual accountability. The Code of Business Conduct and Ethics applies to all directors, officers – including our chief executive officer, chief operating officer and chief financial officer – Team Members, consultants, vendors and agents of the company, regardless of where they perform their work. The global chief compliance officer oversees investigations of all questions, matters, associations and issues related to, but not limited to, potential conflicts of interest, community and political activity and contributions, and prohibited receipts and payments, utilizing appropriate company and outside resources. Anti-Corruption: The operational compliance committee identifies and evaluates situations arising in the course of business and other activities to ensure that licensed gaming is conducted honestly, competitively and free from criminal or corruption elements. Our Anti-Corruption Policy prohibits bribes to governed officials, payment or receipt of commercial bribes or kickbacks, and facilitation payments, and requires proper recordkeeping to ensure payments and financial activity do not fall into any of these categories. Tax: Sands views tax contributions as an essential part of social responsibility. We are committed to paying taxes in the jurisdictions where we generate revenue and doing so in accordance with the laws and regulations of those jurisdictions. Within our three major tax jurisdictions, our tax responsibilities include gaming tax, income tax, transactional tax (goods and services tax and sales tax), property tax, payroll taxes and other specialized taxes. Controls and detailed procedures that ensure compliance include financial accounting and reporting of taxes, tax returns, tax audits, review of implications for new or non-routine transactions, and transfer pricing guidelines in the jurisdictions in which the company operates and aligned with the arm’s length principle. Our Tax Risk Management Policy and Guidelines is utilized on a global basis to help ensure the company meets its compliance requirements with regard to tax matters. Adherence to this global policy is tested in connection with our annual global internal control over financial reporting and certain internal audits conducted by our audit services group as required by the various gaming control boards that our gaming operations comply with in Macao and Singapore. Training and Communications Each year, Sands TeamMembers are required to certify their understanding of and compliance with the terms outlined in the Code of Business Conduct and Ethics and its related policies by electronically acknowledging that they have received and reviewed these materials. In addition, TeamMembers undergo annual compliance training through e-learning modules that cover conflicts of interest, anti-corruption and specific anti-corruption practices related to casinos, payments and expenses, third parties, and recordkeeping and reporting. Compliance training is also conducted annually for the board of directors. An anonymous Ethics Hotline is available 24 hours a day, 7 days a week to all TeamMembers and the general public for web and phone reports of any possible violation. Evaluation and Adjustments We have established processes to inform senior management and other appropriate personnel of significant events related to ethics and business conduct concerns, and periodically review company procedures to ensure we can adequately detect matters requiring review. In addition, our audit services group annually audits various sections of our compliance plan and reports findings to the corporate compliance committee and the local operational compliance committee. MANAGEMENT APPROACH ETH I CAL CONDUCT 2022 ESG REPORT 86
RkJQdWJsaXNoZXIy MTYzNzU=