Preamble
Participation in political activities, whether directly or through involvement with a trade association or other organization, is important for achieving the business objectives of Sports Gaming Global Ventures, LLC. It is also critical that all our activities in this area display rigorous compliance with applicable laws, regulations, and our own code of ethics. For this reason, Sports Gaming Global Ventures, LLC’s essential policy regarding political activities is set forth in the Company’s Code of Conduct. This statement provides additional amplification of the Company’s implementation and compliance activities in connection with that basic policy.
Key Implementation Statements
The primary responsibility for implementing Sports Gaming Global Ventures, LLC’s political and trade association activities lies with the Company’s Political Activities Council (“PAC”) organization, which ultimately reports to the Company’s Executive Vice President (a direct report to our Chairman and CEO). The PAC organization operates throughout the business footprint of Sports Gaming Global Ventures, LLC, including Washington, D.C. The PAC’s political activities encompass the development and advocacy of public policy, lobbying, participation in various trade associations, involvement in several intergovernmental associations, and partnerships with other companies in the casino and sports wagering, broadcast, cable, and satellite industry, as well as third-party organizations on public policy issues relevant to the Company. The PAC team’s work is regularly reported to senior management and the board of directors.
The Company’s political activities, both direct and through trade association participation, aim to influence a wide range of public policy issues impacting the business. These activities include supporting candidates aligned with the Company’s concerns and advocating for relevant issues and legislation. Key issues include legislation and regulation related to sports betting, the distribution of audio and video content over our uplink/downlink facility, local and state broadcasting laws and regulations, Internet and Audio/Video-On-Demand services regulation, and various general legislative and regulatory initiatives affecting Sports Gaming Global Ventures, LLC, such as tax, labor, and workplace safety issues.
Requests for corporate and political action committee contributions are made by members of the PAC organization or by business leaders of the Company through a PAC organization member. All such requests undergo a rigorous review process, and all contributions are ultimately approved by the Vice President of Administration and the Executive Vice President, with reviews by inside and/or outside legal counsel as appropriate. No financial contributions will be made in anticipation of, in recognition of, or in return for an official act. Management provides an annual report to the board of directors on the Company’s political activities, including all political contributions. The Governance and Directors Nominating Committee of the board, composed entirely of outside directors, oversees the company’s political activity, receives the annual report, and periodically reviews this statement.
As outlined in the Sports Gaming Global Ventures, LLC Code of Business Conduct, employees are prohibited from causing corporate or Super-PAC contributions without following this vetting process. Employees must also have gifts to and entertainment of government officials vetted in the same manner. Employees will not be reimbursed directly or through compensation increases for personal political contributions or expenses.
Sports Gaming Global Ventures, LLC also engages in activities with various trade organizations and chambers of commerce. These trade organizations, primarily composed of cable industry associations, aim to advance the common goals and interests of member companies and their customers. Participation in all trade associations requires approval from the Executive Vice President. Sports Gaming Global Ventures, LLC will not pressure or coerce employees to make personal political expenditures or retaliate against employees who choose not to. These principles were fully adhered to in 2024.
From a compliance perspective, the Company prioritizes adherence to all applicable laws and regulations concerning political contributions. We regularly consult with both internal and external counsel to design and monitor our political activity compliance program. All financial contributions, if any, are publicly disclosed as required by law, including disclosures mandated by federal law to the Federal Election Commission and comparable requirements in many states and localities.