Code of Conduct | JACK Entertainment

What are the Company’s Expectations for All Team Members?

Each of us is responsible for understanding and complying with the Code, the law, and Company policy at all times. As a team member, you must act with integrity, use good judgment, and avoid even the appearance of improper behavior. If in doubt about a course of conduct, ask yourself:

• Is it consistent with the Code and Company policy?
• Is it ethical?
• Is it legal?
• Would I want to read about it in the newspaper?

If the answer is “No” to any of these questions, don’t do it. If you are still uncertain, ask for guidance. The Code tries to capture many of the situations that team members will encounter but cannot address every circumstance. You can always seek guidance from any of the following:

• Your team leader
• The Company’s Human Resources team
• The Company’s Compliance team
• The Company’s Legal team

What are the Company’s Expectations for Team Leaders?

As a team leader, you should model appropriate conduct, ensure your team members understand their responsibilities under the Code and other Company policies, and create an environment where team members are comfortable raising concerns without fear of retaliation. You should never encourage others to achieve business results at the expense of ethical conduct or compliance with the Code or the law.
If a team member approaches you with a question or concern related to the Code:

• Listen carefully and give your complete attention.
• Ask for clarification and additional information.
• Answer any questions that you can but seek help if needed before providing a response. Tell the team member that you need to seek further assistance and will provide an answer as soon as possible.

If a team member raises a concern that may require investigation under the Code, contact your Human Resources, Compliance, or Legal team leadership.

Raising and Addressing Concerns

If you observe behavior that may be a violation of the law, the Code or Company policies, raise the issue promptly. Doing so will allow the Company an opportunity to immediately address the issue. You may contact any of the following to raise your concerns or ask any questions you might have about the Code:

• Your team leader
• The Company’s Human Resources team
• The Company’s Compliance team
• The Company’s Legal team

If you are uncomfortable raising your concerns to a team leader or the above resources, you can report suspected violations of the Code or Company policy or any type of illegal, unethical, or unsafe behavior at work by calling the Ethics Hotline at 1-844-591-0568 or by visiting www.jackentertainment.ethicspoint.com. The Ethics Hotline is available to you 24 hours a day, 7 days a week, and you may use it to report your concerns anonymously.

The Company investigates possible violations of the law, this Code, and Company policies, as well as any other behavior that could harm the Company’s reputation and business interests. The Company investigates these matters as promptly and confidentially as possible, determines whether a violation has occurred, and takes appropriate corrective action. You are expected to cooperate fully with such investigations and answer all questions completely and honestly.

No Retaliation

Any retaliation against a team member who in good faith raises a concern about a suspected violation of the law, Code or Company policies is prohibited.
If you work with someone who has raised such a concern, you must continue to treat that person with courtesy and respect. If you believe someone has retaliated against you or another team member, report the matter promptly to Human Resources, the Legal, or Compliance Teams. If you are uncomfortable doing so, you may report your concerns, including anonymously, to the Ethics Hotline at 1-844-591-0568 or www.jackentertainment.ethicspoint.com.
You should use your reporting rights responsibly, without intending to harass others or report trivial matters. It is a violation of the Code and Company policy to knowingly or willfully make false or misleading accusations. Honest reporting does not mean that you have to be right when you raise a concern; you just have to believe that the information you provide is accurate.

Equal Employment Opportunity

The Company is committed to providing equal employment opportunities to all team members and applicants for employment and complying with all applicable laws that prohibit workplace discrimination, harassment, and unlawful retaliation. The Company will promptly and thoroughly investigate all reports of discrimination, harassment, and retaliation, preserve the confidentiality of the investigation to the greatest possible extent, and take immediate and appropriate remedial action if warranted.

Company Assets

Company assets should be protected and used responsibly and in the manner intended. The Company’s assets include everything from physical assets (such as Company money, product, vehicles, or equipment) to intellectual property assets (such as our patents, trademarks, or trade secrets) and everything in between (such as team members’ time at work and work product).
You are responsible for properly using and caring for the Company assets entrusted to you and preventing their loss or misappropriation. You should refrain from using Company assets for your own personal benefit or the benefit of anyone other than the Company. When using Company assets, use common sense and comply with all Company policies. For example:

• Do not engage in personal activities during work hours that may interfere with or prevent you from fulfilling your job responsibilities.
• Do not engage in excessive personal use of your Company phone, computer or e-mail account in violation of the Acceptable Use Policy.
• Do not use Company systems or equipment for outside business, or to access or distribute obscene or offensive media or otherwise violate the Company’s policies or applicable law, including copyright, trade secret, patent or other similar intellectual property laws.
• Do not take for yourself any opportunity for financial gain that you learn about because of your position at the Company, or through the use of Company property or information, without prior approval from the Company’s General Counsel.

Business and Financial Records

Accurate recordkeeping and reporting reflects on the Company’s reputation and credibility and allows the Company to meet its legal and regulatory obligations. Ensure that all Company business and financial records that you either create or are responsible for based on your job duties are accurate, complete and conform to applicable legal and regulatory requirements, accounting principles, and the Company’s internal control standards. Keep the following in mind when creating business or financial records on behalf of the Company:

• Never falsify a document and
• Never distort the true nature of any transaction.

Always cooperate fully with our internal and external auditors, our Legal and Compliance teams, and any regulatory authorities and provide them with full, fair, accurate, timely and understandable information and reports. You may report any concerns about financial, accounting and auditing matters, as well as any issues related to Company records, through the appropriate Company channels described in this Code.

You should create, retain, and discard Company records and information in accordance with the Company’s Records Retention Policy and any applicable Company or team-specific policies, procedures, and schedules. Comply with the Legal team’s instruction when records should be preserved for potential or pending litigation or investigations or in response to court orders. Failure to abide by such instruction could expose the Company and/or team members to serious legal and financial consequences.

Confidential Information

You must safeguard and maintain the confidentiality of any non-public information entrusted to you as a team member that might be of use to competitors, or harmful to the Company or its guests, suppliers, or business partners, if disclosed, except when disclosure is authorized or legally required. Hold the personal information of current and former Company team members and their beneficiaries in strict confidence. Your obligation to protect such non-public information extends outside of the workplace and working hours and continues even after your employment with the Company ends.

The Company respects the privacy of its team members, guests and business partners and handles all personal data responsibly and in compliance with all applicable laws. Team members who handle the personal data of others must:

• Comply with applicable laws and any relevant contractual obligations;
• Collect and use such information only for legitimate business purposes;
• Limit access only to those with a legitimate business purpose for such information; and
• Take care to prevent any unauthorized disclosures.

Inquiries from the Media and Others

You may not answer questions on behalf of the Company from the media, analysts, investors, or other members of the public, without authorization from the Chief Marketing Officer. Only team members delegated such authority within the scope of their job duties may speak to such third parties on the Company’s behalf. Any requests for information must be directed to the Company’s Chief Marketing Officer.

Notification of Arrest or Legal Proceedings

You must immediately notify Human Resources if you are arrested, charged with a crime, plead guilty to a crime, or are issued a criminal complaint or other legal process in connection with your potential criminal violation of federal or state law. Failure to do so within five (5) working days of your arrest may result in improvement action up to and including termination. Licensed team members also may have individual reporting obligations to the applicable licensing agency and are solely responsible for that reporting.

Team Member Gaming

The Company has adopted a Team Member Gaming Policy to ensure compliance with applicable gaming laws, rules, and regulations, and maintain consistent customer service standards at all of the Company’s gaming properties. You should refer to the Team Member Gaming Policy for an explanation of what you can and cannot do with respect to gaming. Failure to act in accordance with this Policy may result in improvement action up to and including termination, loss of licensure and/or criminal penalties.

Improper Payments, Gifts or Political Contributions Are Prohibited

Company funds and property must be used for legal, ethical, and otherwise proper purposes only. Never seek to influence public officials, other companies, or private citizens through the payment of bribes, kickbacks or any other unethical payment or gift. Such activity calls the Company’s integrity into question and, in most cases, violates the law.

You must be particularly careful when dealing with public officials as such transactions are covered by special legal rules that carry severe sanctions, including monetary fines and imprisonment, if violated. Always obtain prior approval from the Company’s General Counsel before providing anything of value (including small items, like a cup of coffee) to a public service agent and ensure that any such payments are properly recorded in the appropriate Company account. Consult with the Company’s Legal team for clarification and guidance.

Although this Code generally does not prohibit you from personally supporting or contributing to political candidates or parties in accordance with applicable laws, some jurisdictions prohibit the Company and its team members from making certain political contributions. Failure to follow these requirements may result in criminal penalties, loss of the team member’s and/or Company’s gaming licenses, and termination of employment. Any questions about political activity or contributions should be directed to the Company’s General Counsel to be evaluated on a case-by-case basis.

Insider Trading

You must keep inside information regarding the Company, its guests, suppliers, competitors, or others, obtained through your position at the Company, confidential. Inside information is material, non-public information that a reasonable investor would consider important in a decision to buy, hold, or sell securities. Do not use such inside information to trade in securities or engage in any other action to take advantage of, or pass along to others, that inside information. Use of inside information for personal gain for yourself or your family members could result in jail time, fines, or both. You should avoid even the appearance of improper transactions to preserve the Company’s reputation for adhering to the highest standards of conduct. Consult with the Company’s Legal team if in doubt about whether you possess inside information.

Conflicts of Interest

When acting on behalf of the Company, you must put the Company’s interests ahead of your own personal gain. Do not allow your own interest or your family or other relationships to influence the decisions you make on behalf of the Company. Because the Company is committed to the highest ethical standards and desires to avoid even the appearance of impropriety, you should avoid even the appearance of such conflicts of interest. This may require you to withdraw from certain business decisions, including those related to the selection of vendors or decisions relating to the employment of others, such as recruitment, promotion, salary, or allocation of duties. You may not engage in any conduct that is disloyal, competitive, or damaging to the Company; interferes with your judgment about the Company’s best interests; or exploits your position with the Company for personal gain.

You must report and disclose all transactions, interests and relationships involving employment, securities, compensation, credit, or loans, beneficial interest in or rights to profits or income that may give rise to an actual or apparent conflict of interest to Human Resources. Such disclosure obligation includes any interest or relationship with any entities that supply or purchase products or services to or from us or compete with us (other than ownership of less than 2% of the publicly traded securities of such a company). If you are uncertain about whether an actual or apparent conflict of interest exists, you must immediately contact Human Resources.

Do not allow your business decisions to be influenced by gifts, favors, loans, or hospitality from others. Accepting or offering gifts, favors, loans, or entertainment can create a conflict of interest, result in the appearance of a conflict and, in some cases, violate the law. As a general rule, team members should not accept such gifts or favors from persons or entities that deal with the Company if the gift might reasonably be perceived to influence the team member’s decisions or actions as a team member. You are responsible to know and comply with all applicable Company or team-specific policies or procedures related to accepting gifts or favors. Gifts that exceed the limitations in the Acceptance of Gifts Policy must be approved in writing by the Company’s General Counsel.