Frequently Asked Questions
Why is it important to report misconduct or policy violations?
We expect all team members to speak up and report suspected violations of our Code of Conduct, our policies, or applicable laws and regulations. Reporting suspected wrongdoing helps maintain our culture of integrity. It allows the Company to address issues that could harm the Company, fellow team members, and our reputation. It can also help us prevent future occurrences of similar violation or misconduct.
How can I seek help, speak up, or report a misconduct?
There are many ways for you to seek guidance or report a concern – choose the way that is most comfortable for you:
- Your direct supervisor or next level manager
- The Human Resources partners
- Your local Compliance team or the Global Compliance Department
- The Legal Department
- The Ethics Hotline, available by phone, web, or mobile
How Can I reach the Compliance Department?
What is the Ethics Hotline?
The Ethics Hotline is a 24-hour reporting tool operated by an independent third-party vendor that provides Sands team members, Fortizens, business partners and others with a confidential means of reporting suspected misconduct, raise a concern, or ask ethics related questions.
Is my report confidential?
All Ethics Hotline reports will be handled confidentially. The identity of the person making the report, the nature of the report itself, and the name(s) of individuals involved and/or participating in the investigation will be kept confidential and only shared on a limited need-to-know basis as necessary to conduct a full and fair investigation, or as legally required by law.
Can I remain anonymous when making a report?
Yes. Reports can be made anonymously through the Ethics Hotline where legally permitted. However, providing your name and contact information would enable the Company to better investigate the allegations. It would allow the investigator to contact you for further information, which may expedite the time it takes the Company to review the matter. All reports, including your details, are treated in confidence as provided above.
Who will be investigating the matter once a report is made?
Once a report is received, an appropriate internal investigation team will review the matter in a fair manner. In very limited situations, the Company may engage appropriate external consultants or law firms to conduct a review.
Am I protected against retaliation?
Yes. The Company strictly prohibits any form of retaliation against anyone who, in good faith, makes a complaint, raises a concern, provides information, or otherwise assists in an investigation or proceeding regarding any conduct that he or she reasonably believes to be in violation of our Code of Business Conduct and Ethics, Company policies, or applicable laws, rules or regulations. The Company prohibits anyone from being retaliated against even if their complaints are not substantiated by an investigation. Individuals are not protected if they knowingly made a false allegation, provided false or misleading information in the course of an investigation, or otherwise acted in bad faith.
What if I am not sure if something is a policy violation or if I just have a question?
Even if you are unsure if what you have observed or became aware of is a policy violation, we still encourage you to raise the issue. We also encourage you to reach out and ask questions or when you are uncertain of a course of action. You may do so with any of the reporting methods mentioned above, via the Ethics Hotline, or by reaching out to Compliance at Compliance@sands.com.
Where can I find Company policies?
You can access Company policies via the links below:
United States, Fortis Holdings, Inc., and Sands Digital Services, Inc.
Policies and Procedures (NAVEX PolicyTech)
Macao & Singapore
Policies and Procedures (NAVEX PolicyTech)
Where can I find more information about data privacy related to the Ethics Hotline?
If you have questions regarding the Company’s data privacy practice, contact us at Privacy@Sands.com.