With a system of checks and balances at all levels of the organization, our colleagues play a vital role in meeting our standards and complying with applicable legal requirements. Our Code of Business Conduct & Ethics (the “Code”) contains general guidelines on the behavior we expect from all our colleagues, including directors and officers and from agents and subcontractors. We require each of our directors, officers and employees to certify their acknowledgement of and compliance with the Code when they join the Group and each time a new version is published.
Code of Business Conduct & Ethics includes,
but is not limited to, the following aspects:
Employment practices to maintain fair, inclusive and respectful workplaces Policy against retaliation Fair competition Conflicts of interest Anti-bribery and corruption Restrictions on giving and receiving gifts and entertainment Confidential and proprietary information Anti-money laundering and terrorist financing
We run three initiatives to help colleagues understand their responsibilities under the Code and the Program:
The Code: corporate governance briefing and annual certification
New hires must complete their corporate governance orientation within the first 30 days of employment. All other colleagues receive the Code and are notified of updates to other corporate governance policies each year. Colleagues must acknowledge they received these documents and sign a Certificate of Compliance to indicate they understand and agree to the content.
The Program: annual certification
Our key personnel, such as directors and senior executives, are required to confirm and acknowledge their understanding of the Program and their reporting obligations under the Program.
Do The Right Thing (DTRT) training
DTRT training provides a refresher for management and colleagues in key business functions that carry a higher risk of potential bribery and corruption, such as procurement and contract approval. The training covers the legal reasons behind the Program, red flags to look out for, and specific actions colleagues can take to reduce risks. To ease access to this information, all the documents and training material are available in multiple formats, including face-to-face training and via our e-Learning platform.
READ MORE IN OUR SUSTAINABILITY REPORT
We provide multiple channels for our colleagues to raise concerns about any potential violation of the Code or wrongdoing. We do not permit retaliation of any kind against any employee who in good faith reports actual or suspected violations. Any colleague who knowingly provides false information may be subject to the usual disciplinary procedures.
All Melco Resorts colleagues, customers, suppliers and other business partners can report potential allegations via the anonymous whistleblowing hotline managed by an external party, or through internal channels, such as supervisors, Ethical Business Liaison Officers, the Ethical Business Adviser, or any Human Resources team member. Details of our whistleblowing channels are discussed at the corporate governance orientation, and are available on our intranet and posted within key employee areas of our resorts.
Our Code of Conduct for Suppliers (Supplier Code) sets our expectations for our suppliers. It not only requires suppliers to meet all applicable legal requirements, but also our ethical, anti-corruption, data privacy and security, human and labor rights, health and safety and environmental standards. All suppliers acknowledge acceptance of the Supplier Code and we provide training and regularly engage with our suppliers directly to assess performance. In 2020, we will share a detailed questionnaire with our suppliers as a first step towards reinforcing our requirements and expectations. This will additionally deepen our focus on sustainable sourcing, and in particular bring new attention to the ethical treatment of animals and practices adopted to prevent and eradicate all forms of human trafficking and forced and child labor in the supply chain.