Our Code of Conduct
Doing
the right
thing
Contents
Version: January 2024
Entain plc | Our Code of Conduct
2
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
04 A message from our CEO
05 Our values
06 Our responsibilities
08 Standards of Behaviour
09 Working with each other
10 Supporting our customers
12 Working with suppliers
13 Modern slavery & human rights
14 Gifts & hospitality
15 Conflictsofinterest
16 Fraud
17 Bribery & corruption
18 Anti-money laundering, counter-terrorist
financing&sanctions
19 Competition & anti-trust
20 Insider dealing & market abuse
21 Tax evasion
22 Privacy, data protection & information security
23 Safeguarding company property
24 External communications
25 Speak out
26 Appendix of Policies and Procedures
A message
from our CEO
At Entain we have set out an ambition to be the
world-leader in sports betting, gaming and interactive
entertainment. In order to achieve this, while delivering
long term value for all of our stakeholders, we have a
clear strategy based on two pillars: sustainability and
growth. In practice, delivering this strategy means:
putting our customers’ interests at the centre of every
decision we make; promoting a best-in-class approach
to corporate governance, regulatory compliance, and
the operation of our business; making Entain the best
place to work by creating an inclusive and rewarding
environment; and working in partnership with the
communities in which we operate.
Ultimately, our success and our reputation depend
on how we conduct ourselves as individuals and as a
business. This Code of Conduct is a summary of the
standards, policies and principles of fair play, honesty
and integrity that underpin Entain. It sets out what we
expect from everyone who works for us and from those
whom we do business with.
Please take the time to read and understand this Code
of Conduct, and if you feel something is not right, or if
you are ever in doubt about the right thing to do, please
speak to your line manager or use our Speak Out Policy
and let us know. We are committed to upholding the
highest standards in everything we do.
Stella David
CEO, Entain plc
This Code of Conduct
is a summary of the
standards, policies and
principles of fair play,
honesty and integrity that
underpin Entain.”
Entain plc | Our Code of Conduct
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A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Our values
Thesefour values(“Values”) guide every decision we
make and action we take. They are vital to our culture
and are at the heart of how we work together, serve
our customers and measure our success.
Doing what’s right is what underpins the spirit and
letter o
f this Code of Conduct. We want to be known
a
s a responsible company that our employees are
proud of and our customers, partners and suppliers
trust. We believe that long term, successful business
relationships are built by being honest, open, and fair.
Entain plc | Our Code of Conduct
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A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
We always put our customers first, leading in player
protection to prevent potential harm We work in an
environment where everyone can be themselves, without
ego, acting with integrity We keep ourselves honest and we
aren’t afraid to speak out if something feels wrong
We make it easy for our customers, focusing on them
a
nd solving for their needs
We’re clear on our goals and who’s accountable for
what, so we all know what success looks like
We remove complexity wherever we find it because
we all perform better that way
We’re always curious, always improving,
learning from success and setbacks to push
forward
We have big ambitions, we surround
ourselves with the best, and we all put in the
effort needed to deliver
We embrace change because that’s when
progress happens
We all have the same vision and purpose, so
we break down silos and share ideas
We
never forget that we’re on the same side,
so we always treat everyone the way we’d
want to be treated
We find inspiration in and celebrate the
successes of our teammates because when
they win, we win
Everyone who works
for or on behalf of
Entain needs to:
Do the right thing – always act in the best interests of the company
and consider the implications of what you’re doing.
Comply with the law. Bear in mind that laws may vary depending
where you work.
Make sure you understand and follow this Code of Conduct,
together with our policies, procedures and industry guidelines.
Speak out if you’re unsure about any legal, ethical or procedural issue
and tell us if you think there’s been a breach of this Code of Conduct.
Our responsibilities
TheaimofthisCodeofConductistohelpguideyourunderstandingofour
Values so that we all uphold the highest standards of behaviour. The Co
de
of Conduct, and the policies and procedures underpinning it, set out what’s
expected of each of us, what we can expect of one another, and how we’re
expected to behave towards customers, and other stakeholders.
Sometimes situations arise where the right decision isn’t
completely clear. This Code of Conduct helps you navigate
such situations. It’s a user-friendly resource that you can rely
on to help determine what’s appropriate when it comes to
acting ethically and with integrity in the workplace.
In particular, this Code of Conduct requires:
¥
honest and ethical conduct;
¥
compliance with applicable laws, regulations and rules;
¥
protection of confidential, personal and
proprietary information;
¥
personal accountability; and
¥
prompt internal reporting of any actual or potential
breaches of the Code of Conduct.
We all are responsible for complying with this Code of
Conduct, the policies and procedures that underpin it, and all
the laws and regulations that apply in the markets in which
we operate.
This includes upholding Entain’s commitment to the
International Bill of Human Rights, including the United
Nations (“UN”) Universal Declaration of Human Rights, and
the International Labour Organisation (“ILO”) Declaration on
Fundamental Principles and Rights at Work.
* Due to different legal requirements in some of the countries we operate in, there may be minor local variations to this Code of Conduct. Where applicable, these will be communicated
separately, but the basic assumption should be that this version of our Code of Conduct applies to everyone. If there’s any conflict between our Code of Conduct and local laws,
whichever contains the higher standard of conduct will apply.
Everyone working for, or on behalf of, Entain (including
employees, consultants, suppliers, and contractors) is
required to behave in accordance with this Code of Conduct*,
regardless of level or function.
Make sure you read this Code of Conduct and the policies
and procedures underpinning it. You can find these on our
intranet and set out (together with links) in the Appendix to
this document. As part of your assigned compliance training,
each year you’ll be required to complete training on this Code
of Conduct and provide confirmation that you have read,
understood, and will follow its requirements.
If you lead a team, its members will look to you as their role
model for doing what’s right. It’s also up to you to make sure
they behave in accordance with this Code of Conduct.
As a manager or leader inside Entain, you must regularly
consider what you can do to ensure that your business or
department is in compliance with this Code of Conduct and
applicable laws and regulations.
Violation of this Code of Conduct (and the policies and
procedures underpinning it) may result in disciplinary action,
including termination of employment, and may also result in
civil and criminal liability.
Entain plc
|
Our Code of Conduct
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A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Further guidance
The Code of Conduct cannot describe every possible situation
that you might encounter through your work.
If you don’t find the guidance you seek in this Code of
Conduct, or in the policies and procedures underpinning it, you
should ask yourself the following simple questions about the
course of action you are considering:
¥
Is it legal?
¥
Does it feel right?
¥
Would I be comfortable explaining what I’m doing to
senior management, my line manager and the Ethics &
Compliance team?
If the answer to any of these questions is ‘no’ or ‘not sure’, then
don’t proceed without seeking further guidance, even if it is
something you’ve been asked to do or you’re told that it’s been
done this way in the past. It’s always better to ask a question,
than to guess or assume an answer.
No one has the authority to make you engage in behaviour
that violates this Code of Conduct (or the policies and
procedures underpinning it).
If you wish to seek further guidance or want to raise a
concern, you can speak to your line manager, or the Legal
& Compliance or Human Resources teams as appropriate.
If you’re not satisfied with the response you receive, or
otherwise feel uncomfortable speaking to your line manager
or another internal team, you may raise your concerns
confidentially under our Speak Out Policy.
Sustainability
The Code of Conduct sits alongside, and supports,
our dedication to sustainability, which is set
out in more detail in our Sustainability Charter
based around four cornerstones of regulation,
responsibility, corporate governance, and people &
communities. We embrace our role within society
and believe that the most sustainable business
in our industry will be the most successful.
Please see here for further information on our
Environmental,Social&Governance(“ESG”)
strategy, including our ESG Factsheet, annual ESG
Reports and detailed ESG Policy Statements.
Entain plc | Our Code of Conduct
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A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Standards of
Behaviour
We have a responsibility to protect the interests of our
shareholders, colleagues, and customers, and to do
our best to help Entain abide by the highest standards
of conduct. Unethical behaviour of any kind, including
behaviour described in more detail below, is contrary to
our Values and is strictly forbidden.
Working with each other
Su
pporting our customers
Working with suppliers
Modern slavery & human rights
Gifts, hospitality & donations
Conflictsofinterest
Fraud
Bribery & corruption
Anti-money laundering, counter-
terroristfinancing&sanctions
Competition & anti-trust
Insider dealing & market abuse
Tax evasion
Privacy, data protection
& information security
Safeguarding company property
External communications
The topics below and the behaviours expected for each will be covered on
the following pages.
Entain plc | Our Code of Conduct
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A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
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Working with
each other
We show our commitment to our
colleagues by doing our best to keep
them safe, valued and rewarded for the
work they do.
Our business relies on people whose energy, commitment,
skills, and experience make Entain the success it is today.
We are proud to have a diverse mix of employees from all
walks of life who make up the worldwide Entain family.
We all play an important role in creating a work environment
in which employees and business partners feel valued and
respected for their contributions and unique characteristics.
Entain has zero tolerance for any form of harassment or
abusive behaviour towards employees, contractors, suppliers,
customers, or anyone with whom we deal.
Key points
¥
We must act with tolerance and empathy and treat each
other with respect.
¥
We must not behave in a way which could be
considered as intimidating, malicious, insulting, offensive
or discriminatory.
¥
We do not tolerate physical or psychological harassment,
bullying, abuse or other offensive behaviour in
the workplace.
¥
We must behave professionally and responsibly when
representing Entain, be it in the workplace or at external
work events.
¥
We are an equal opportunity employer and never
discriminate based on age, gender, race, religion,
national origin, sexual orientation, disability, or any other
classification protected by applicable law. This is true
at each stage of employment, including recruitment,
job assignment, promotion, remuneration, training, and
benefits. We will take action against, and not tolerate,
cases of discriminatory behaviour or harassment.
¥
We do not permit drinking alcohol (unless at a company
event), taking non-prescription drugs, or being under the
influence of either of them at work, and if drinking at a
work event we must do so moderately, responsibly and
behaving appropriately.
¥
We are committed to providing a safe work environment
which promotes our people’s safety, health, and wellbeing.
We need everyone to set an example of good behaviour.
That includes:
¥
taking personal responsibility for our own health, safety,
security and wellbeing, as well as that of our colleagues;
¥
challenging and reporting unsafe or inappropriate acts
and conditions;
¥
contributing ideas to improve working practices;
¥
following all relevant safety policies, procedures, guides,
and briefs - these are here to assist you but, of course,
they are not so set in stone that we cannot deviate if it
means avoiding or preventing harm; and
¥
stopping what you are doing and asking for advice or
assistance if you are unsure about any health, safety,
security, or environment issues.
Further information on rules and standards
¥
Environmental Policy Statement
¥
Health, Safety, Wellbeing & Workplace Policy Statement
¥
Your local Human Resources and Health & Safety policies
which are available on Entain.me or from a member of the
Human Resources team.
¥
Entain provides an Employee Assistance Programme
(“EAP”), a free and confidential service delivered to help
colleagues deal with personal circumstances that might
adversely impact their work performance, health and/or
wellbeing. Further advice is available to colleagues via our
intranet, their line managers, Human Resources and posters.
Q
I notice a loose carpet that might cause an injury if
someone in the office or the retail shop trips over it.
What should I do?
A
Report the safety risk to your line manager or to the
safety management centre (SMC) in your area so that
it can be made safe.
Q
I have a concern with how someone is being treated
at work by another colleague. Who can I speak to?
A
Your first port of call should be your line manager or
your local Human Resources team. Our Grievance
Procedure is also a way to raise normal Human Resources-
related issues and workplace grievances. If you feel more
comfortable raising the issue in another manner, consider
using our Speak Out reporting system.
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
10
Supporting
our customers
We want to provide a safe and trusted
betting, gaming, and interactive
entertainment experience for all our
customers.
This means we aim to provide our customers with exciting
products and experiences, supported by the best possible
player protection and customer service, while always aiming
to do better.
For the vast majority of our customers, betting and gaming
is a source of fun and entertainment. But we know that for a
small but significant number, it can become harmful to them
and their families. We have a responsibility to them. That’s
why we want to encourage sustainable betting and gaming
and minimise addiction and the related harm it can cause.
Taking a lead in tackling problem betting and gaming, we
focus on understanding the issues, designing for safety,
empowering our customers, helping those who need support
and educating ourselves and our stakeholders.
ARC, our award-winning safer gaming programme, goes
from strength to strength. We’re seeing a reduction in
high-risk customers and more and more customers setting
gambling controls.
On top of our pioneering technology and algorithms, we have
a network of highly trained colleagues, online and in our
shops, who act on signs of problem betting and gaming and
make sure our customers get the support they need.
Our ambition is to be a sustainable business focused on the
long term wellbeing of all our customers. We all have our part
to play.
Key points
¥
We must all help Entain to be professional, courteous,
diligent, and accountable towards our customers.
¥
We must spot risks as early as we can and intervene to
prevent problems before they get out of hand. Make sure
you read and understand our approach to Safer Gambling
and other related policies which may apply to you.
¥
We must complete our assigned training, and review and
improve our procedures on a regular basis to keep our
customers and colleagues safe.
¥
We must do our best in relation to customer service: being
professional, attentive, and customer-focused; seeking to
understand our customers’ issues or questions; and aiming
to resolve any problems as soon as possible.
¥
If you are a manager, make sure your team understands
their role in promoting safer gambling.
¥
Make sure you are up to date with Entain’s Anti-Money
Laundering & Counter-Terrorism Financing (“AML”) policies
and procedures that relate to your role or business.
Remember that customers showing a pattern of increasing
spend, or spend inconsistent with their apparent source of
income, could be an indicator of potential money laundering
activity, as well as a potential safer gambling risk.
¥
For colleagues in customer facing and shop teams, it’s key
that you stay alert to potential customer signs of problem
gambling and escalate cases promptly in accordance with
local procedures.
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Our ambition is to be a
sustainable business focused
on the long term wellbeing of
all our customers. We all have
our part to play. ”
Entain plc
|
Our Code of Conduct
11
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Q
A customer makes contact saying they can’t access
their account. What should I do?
A
Make sure to take the customer through the relevant
data protection and password reset processes,
keeping a close eye on whether it may be fraud or someone
else trying to access the account. This will allow the
customer to access their account quickly and safely or
prevent unauthorised access to the account.
Q
During a customer interaction, a customer mentions
that they’ve borrowed money for their gambling.
How do I handle that?
A
There are several potential issues with the account
and so it should be escalated to the relevant customer
protection department following your local escalation
processes. This will ensure that any potential issues can be
properly evaluated by the relevant, specialist team who will
be best placed to help the customer.
Q
I’m always busy and so I don’t have time to do
my training, is it ok to skip it this year and do it
next time?
A
No, all mandatory training needs to be done within
the stipulated timelines. You should raise it with
your line manager so that time can be allocated to doing
the training.
Q
An employee involved in the Product Team becomes
aware of a game that is not performing as it is
supposed to. How should they deal with the problem?
A
In all situations where a game is not performing as
designed, we need to be fair and transparent with
our customers and potentially notify regulators. Therefore,
it’s important to remove the game while the malfunction
can be investigated and to report the malfunction to the
Compliance team.
Examples
¥
For all colleagues conducting customer interactions, make
sure you follow our latest procedures, use the information
that’s available to you, clearly document any actions taken
and the reasons for those actions, and always ask for
support if you need it.
¥
For our Product and Marketing teams, remember to give
focus to safer gambling in terms of product design and
marketing strategies and follow any internal policies and
procedures in this regard.
Further information on rules and standards
¥ Global Safer Gambling Statement
¥ External Marketing Policy Statement
¥ Ask your line manager or the Legal & Compliance team for
Safer Gambling and AML policies that apply to your role,
local market or business.
On top of our pioneering
technology and algorithms,
we have a network of highly
trained colleagues, online and
in our shops, who act on signs
of problem betting and gaming
and make sure our customers
get the support they need. ”
Supporting our customers continued ...
Entain plc
|
Our Code of Conduct
12
Working
with suppliers
We expect our suppliers to comply with
core compliance standards, principles,
and policies.
We recognise that to be a world-leading company, we need
to adhere to the highest standards of ethical behaviour in all
areas of our operations and across our supply-chain. As part
of this, all Entain suppliers must adhere to the minimum
standards outlined in the Supplier Code of Conduct and
ensure their own suppliers do the same.
By entering a business relationship with us, all suppliers
are deemed to have accepted the obligations set out in the
Supplier Code of Conduct and to have agreed to comply with
it in addition to their contractual and other obligations.
Any breach of the obligations contained within the Supplier
Code of Conduct may be considered a material breach of
contract by the supplier.
Key points
¥
Suppliers must comply with all laws, regulations, and codes
of practice applicable to their business, including financial,
human rights, environmental and employment laws.
¥
In the context of providing services to Entain, suppliers
must promptly notify Entain of any actual or potential
breach of any such laws, regulations, or codes by them.
¥
Employees must follow our procurement procedures,
including supplier onboarding procedures, payment
processes and supplier screening requirements, to ensure
that we are working with reputable entities and we
protect Entain.
Further information on rules and standards
¥
Supplier Code of Conduct
¥
Procurement Policy*
¥
Global Payment Processing Policy*
¥
Anti-Bribery, Corruption & Tax Evasion Due
Diligence Procedure**
* Only available to those on Oracle ** Not available for general distribution
Q
A proposed supplier is refusing to agree to comply
with our Supplier Code of Conduct on the basis that
they already have their own compliance policies and
procedures.
A
It’s a requirement of our procedures that all proposed
suppliers agree to comply with the Supplier Code of
Conduct. The fact the supplier has their own compliance
policies and procedures doesn’t change this. If the
supplier’s own policies and procedures are adequate, then
compliance with our Supplier Code of Conduct shouldn’t
involve any additional effort (and so they should not have
reason to object). In exceptional circumstances, where
a supplier is essential to our business and they continue
to refuse to agree to comply with our Supplier Code of
Conduct, the Ethics & Compliance team may waive the
requirement. However, this waiver may only be granted
where the Ethics & Compliance team is satisfied that the
supplier’s own compliance policies and procedures are an
adequate substitute for our Supplier Code of Conduct.
Q
I have become aware of press articles that a
supplier we have been working with for years has
been implicated in paying bribes.
A
You should immediately report this to the Legal &
Compliance team or otherwise in accordance with
the Speak Out Policy. Under applicable anti-corruption
and bribery laws, Entain may in certain circumstances
be held liable for the actions of third parties such as the
supplier and it will, therefore, be important for the Legal &
Compliance team to investigate whether bribes may have
been paid in relation to Entain business.
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Examples
Entain plc
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Our Code of Conduct
13
Modern
slavery &
human rights
We are committed to making a positive
contribution to human rights and
to help prevent slavery and human
traffickinginallforms.
We respect the dignity and human rights of our workforce and
the individuals with whom we interact.
We are committed to upholding internationally recognised
standards relating to human rights, including the UN
Universal Declaration of Human Rights, UN Global Compact,
UN Guiding Principles on Business and Human Rights,
Children’s Rights and Business Principles, and ILO Declaration
on Fundamental Principles and Rights at Work.
Even today, slavery and human trafficking happens. Such
‘modern slavery’ can take many forms including forced labour,
child labour and sweat shops. In most cases, modern slavery
uses force, threats, deception, or coercion. Victims may have
been abducted or forced to live somewhere against their will.
We have a legal and moral obligation to ensure that Entain,
as well as our suppliers and partners, does not knowingly or
unwittingly support or participate in modern slavery or human
rights abuse.
If you suspect that slavery, human trafficking or human rights
abuses are taking place, you should report it as soon as
possible under the Speak Out Policy.
Key points
¥
Make sure you understand our internal training and
guidance, including relevant procurement and human
resources procedures, to know how to identify potential
cases of modern slavery.
¥
Do not knowingly work with any supplier that is or may be
infringing the human rights of its workers or not complying
with applicable laws such as those relating to modern
slavery, labour conditions and health and safety.
¥
We, and all those who provide services to us or work on our
behalf, must:
¥
not use forced or compulsory labour (i.e., any work or
service that a worker performs involuntarily or under
threat of penalty);
¥
comply with the minimum age requirements prescribed
by applicable laws;
¥
compensate workers with wages and benefits that meet
or exceed the legally required minimum for that country;
¥
abide by applicable laws concerning the maximum hours
of daily labour; and
¥
take reasonable steps to ensure that any sub-
contractors or suppliers from whom they source goods
and/or services for ultimate use by Entain also adhere to
these requirements.
Further information on rules and standards
¥
Group Modern Slavery & Human Rights Policy
¥
Supplier Code of Conduct
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Q
I’m concerned that an employee of one of our
suppliers appears frightened. The agency providing
them drops them off and collects them and they appear
to be closely controlled by their manager.
A
These are among the classic warning signs or ‘red
flags’ of modern slavery. You should report your
concerns via the Speak Out Policy. Regardless of whether
this employee of our supplier is in fact the subject of
modern slavery, we owe a moral duty to ensure that all
those who work for us or on our behalf are treated with
dignity and respect.
Entain plc
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Our Code of Conduct
14
Gifts,
hospitality &
donations
We must never give or receive
inappropriate gifts, hospitality or
donations
.
It can sometimes be hard to judge whether a gift or hospitality
is a token of appreciation or something more. While gifts and
hospitality are sometimes acceptable as part of a normal
business relationship, if they are given in return for a favour or
advantage, this may be considered a bribe. This is particularly
the case if we are going through a tendering process, signing a
new contract, or otherwise seeking new business.
All gifts, hospitality and donations offered or received by or on
behalf of Entain and its employees must be of reasonable
value and in compliance with the Group Gifts, Hospitality &
Donations Policy, and applicable anti-bribery and corruption
laws. They should never affect (or appear to affect) impartial
decision-making, which should always be based on factors
such as quality, value, experience, skills, and service.
Key points
¥ Gifts or hospitality can only be given or received where they
serve bona fide business purposes and comply with our
Group Gifts, Hospitality and Donations Policy.
¥ Pre-approval is required for any gifts or hospitality given to
or received from a public official.
¥ Pre-approval is required for any gifts or hospitality given to
or received from a non-public official above the financial
threshold set out in the Group Gifts & Hospitality Policy (or a
lower local threshold).
¥ Pre-approval is required
in advance of charitable donations
on behalf of Entain.
¥ We never make political donations.
Further information on rules and standards
¥ Group Gifts,
Hospitality & Donations Policy
¥ Group Anti-Bribery & Corruption Polic
y
Q
I’m proposing to take a local councillor out for a
modest lunch. Do I need prior authorisation?
A
Yes. As a local councillor is a public official, any gift
or hospitality given to them (regardless of value and
whether modest or otherwise) requires pre-approval under
the terms of the Group Gifts, Hospitality & Donations Policy.
Q
I was invited to attend a football match by a
supplier. I know that the ticket value is below the
£200 reporting and approval limit, but there are likely
to be extras that will push the value higher. What
should I do?
A
Although this hospitality might seem to fall below
our reporting threshold of £200, it is a good idea
to consider the overall value of the hospitality and still
notify your line manager via the Gift and Hospitality
Approval Form out of an abundance of caution.
The reporting can be found on ServiceNow. If you cannot
access ServiceNow contact the Legal & Compliance
team who will help you with a paper-based form.
Certain markets may have lower reporting thresholds,
and if you are unsure of what to do please ask the Legal &
Compliance team.
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
15
Conflicts
of interest
We must always act in the best
interest of Entain.
A conflict of interest is a set of circumstances that creates
a risk that your ability to apply your judgement in the best
interests of Entain is, or could be, impaired or influenced by a
secondary or personal interest. For example:
¥
being employed elsewhere while also working for Entain,
or working for a competitor where other employment
is permitted;
¥
working with a relative, spouse or partner;
¥
using confidential information about somebody to
your advantage;
¥
having a personal or financial interest in a supplier,
customer or competitor that influences or could influence
your decisions at work; or
¥
using Entain resources for personal use.
Conflicts of interest include both the situations where an
actual conflict of interest occurs or could occur, and those that
could give rise to a perception of a conflict of interest.
Key points
¥
You should always act in the best interests of Entain,
maintain the highest possible standards of integrity in your
business relationships and never use your authority or
position for personal gain.
¥
All conflicts of interest (actual or potential) must be
declared in line with the Group Conflict of Interest Policy.
¥
New joiners must declare their actual or potential conflicts
of interest when joining Entain (or confirm that they do not
have any).
¥
Sometimes a declaration may be sufficient but, on
occasions, you may need to manage carefully a perceived
or potential conflict. You, your line manager and Human
Resources should agree the best way to manage the
situation. This may include removing yourself from the
business area or situation that is in conflict.
Further information on rules and standards
¥ Group Conflict of Interest Policy
Q
One of the potential suppliers tendering for a
contract with us is run by my cousin. I’m not
responsible for selecting the successful company in
the tender. Does that mean I don’t need to take any
further steps?
A
While there may not be a formal conflict of interest
as you don’t have responsibility for selecting the
supplier, there’s still a risk that negative conclusions
may incorrectly be drawn or that circumstances may
change in the future. To help manage this risk, you
should declare the potential conflict of interest under
the Group Conflict of Interest Policy.
Q
I’ve become good friends with a key customer
and she has invited me to go on holiday with
her and her family. I would be paying my own share
of expenses. Do I still need to declare this?
A
Yes. While personal relationships may develop
alongside business ones, it’s important to ensure
that this does not give rise to a conflict of interest or
the perception of the same. You should, therefore,
declare the proposed holiday. To the extent you’d
be accepting any gifts or hospitality that you’re not
paying for yourself, you should also comply with the
requirement for pre-approval under the Group Gifts,
Hospitality & Donations Policy.
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
16
Fraud
We must never use dishonesty to gain
an advantage, cause loss or avoid an
obligation.
Fraud involves dishonestly acting (or failing to act) to
gain an advantage, cause loss or avoid an obligation.
Some behaviour that can fall within the definition of fraud
include: theft; forgery; falsification of documents; improper
use of confidential information; misappropriation or use of
company assets for personal gain; unauthorised or false
invoicing or accounting; using related parties without proper
conflict of interest disclosure; knowingly generating or
paying false claims or invoices; and misrepresentation of
accounting entries.
Key points
¥
You must act with the highest standards of honesty,
propriety, and integrity in the exercise of your duties.
¥
You must not be dishonest in doing business.
¥
You must ensure that all documents you produce or oversee
are fully accurate, complete, and not misleading.
Further information on rules and standards
¥ Group Anti-Facilitation of Tax Evasion Policy
¥ Group Conflict of Interest Policy
¥ Global
Payment Processing Policy*
¥ Procurement Policy*
¥ Group Insider Dealing & Inside Information Policy*
* Only available to those on Oracle
Q
I’m aware that a colleague has submitted false
expenses for a recent work trip. What should I do?
A
While it can feel uncomfortable to report the
wrongdoing of colleagues, we all suffer when our
rules are broken, and we all benefit from ensuring that
the highest standards of honesty, propriety and integrity
are followed. You should, therefore, report the issue to
either the Legal & Compliance team or under the Speak
Out Policy.
Q
As part of filling out a questionnaire for licensing,
we’ve been asked whether we’re aware of any
potential breaches by the business of local law. I’m
aware of a minor issue in the past, but it’s now been
fully resolved and the authorities would never find out
about it. Do I need to refer to it in the questionnaire?
A
Failing to disclose information where you are under
a duty to do so to secure an advantage (in this
case, a licence) can in certain circumstances amount
to fraud and were this to come to light at a later stage,
both you personally, and Entain, could face very serious
consequences. You should immediately discuss the
issue with the Legal & Compliance team who can help
determine whether and, if so, how a disclosure should
be made.
Examples
Fraud involves dishonestly
acting (or failing to act) to gain
an advantage, cause loss or
avoid an obligation.”
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
17
Bribery
& corruption
Entain has zero tolerance for all bribery
and corruption, in whatever form,
anywhere in the world.
Our policy at Entain is simple – offering, giving, requesting, or
accepting any form of bribe is unacceptable, whether directly
or indirectly.
Bribes can come in different forms and do not have to involve
cash changing hands. They can be made by giving gifts (such
as holidays, tickets to an event or meals out), via charitable
or political donations or through hiring decisions (such as by
employing a family member of a decision-maker).
Sometimes, bribes can take the form of so-called ‘facilitation
payments’, which are typically small payments or gifts given
to a public official to encourage or speed up the performance
of an existing duty or obligation (such as issuing work
permits, releasing goods from customs, or granting a licence).
Such payments are also not permitted.
Bribes may also be offered to Entain employees by potential
suppliers, who may then expect to win a tender or get
preferential treatment.
Key points
¥
You must not offer, give, request, or accept any improper
financial or other advantages.
¥
You must not offer or give any financial or other
advantages, or make any facilitation payments, to
public officials.
¥
Pre-approval is required in advance of political or charitable
donations on behalf of Entain.
¥
Pre-approval is required in advance of any lobbying of
public officials and a record of any such interactions must
be logged, as set out in the Anti-Bribery, Corruption & Tax
Evasion Procedural Framework.
¥
You must not use work time or resources to engage in
personal political activities without specific prior approval.
¥
Consult our Group Anti-Bribery & Corruption Policy if
a potentially improper or facilitation payment may be
needed to avoid imminent danger (such as an immediate
threat to the personal health, safety or freedom of you or
your family).
¥
Immediately report anything to the Legal & Compliance
team that you suspect might be a bribe.
Further information on rules and standards
¥ Group Anti-Bribery & Corruption Policy
¥ Anti-Bribery, Corruption & Tax Evasion
Procedural Framework**
¥ Anti-Bribery, Corruption & Tax Evasion Due
Diligence Procedure**
¥ Group Gifts, Hospitality & Donations Policy
*
* Not available for general distribution
Q
We’re proposing to hire a consultant to help us
secure a licence in a country. What should I do to
help ensure we comply with our rules on anti-bribery
and corruption?
A
You’re right to check as Entain can be held liable not
only for our own actions but also for failing to prevent
bribery by third parties who perform services for or on our
behalf. Therefore, it’s important to ensure that all proposed
suppliers go through our onboarding procedures, including
the Anti-Bribery, Corruption & Tax Evasion Due Diligence
Procedure, before starting work. This ensures that any
risks can be assessed and, if appropriate, dealt with. This is
especially important where, as here, the supplier may
interact with public officials (as this is a higher risk area for
bribery and corruption).
Q
I’ve been told that, to apply for a licence in a
country, we need to make a donation to a specific
local charity. Should I approve the donation?
A
No. While charitable contributions can be a legitimate
part of a local licensing process, they can also be
a route for bribes to be requested and paid. As such,
charitable contributions made on behalf of Entain are
prohibited unless they are approved in advance according
to the process set out in the Group Anti-Bribery &
Corruption Policy. As part of that process, additional checks
will be made, and advice taken, to confirm whether the
charitable contribution is legitimate and appropriate.
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
18
Anti-money
laundering,
counter-
terrorist
financing &
sanctions
We must act responsibly to keep
financialcrimeoutofgambling.
Money laundering refers to the use, concealment, or
processing of property which you know or suspect represents
(in whole or in part) a benefit from criminal activity, regardless
of whether that activity is by third parties or Entain and
regardless of where it takes place. One type of money
laundering that occurs frequently in practice is when the
proceeds of crime are converted or disguised by being spent
or invested in legitimate activities. This could be by purchasing
properties or goods or, particularly relevant to our business, by
betting, gaming, or engaging in interactive entertainment (i.e.,
by converting proceeds of crime into winnings). Keeping this
money out of gambling is an important part of our regulatory
and ethical obligations.
Terrorist financing refers to the raising, moving, storing, and
using of financial resources for the purposes of terrorism.
Money laundering can include the use, concealment
or processing of property that has arisen because of
terrorist financing.
Sanctions refer to restrictions placed on certain countries,
companies or people which prevent others from engaging in
or facilitating prohibited transactions with them.
Key points
¥
Keep an eye out for suspicious activity or transactions.
¥
Report any knowledge, suspicion, or concerns you may
have immediately under the procedure set out in the Group
Anti-Money Laundering & Counter-Terrorist Financing
Policy. Remember that you do not need to be 100% sure of
the facts, so long as you feel there is suspicious activity.
¥
Do not tell someone that you have made a report about
them or that they are under investigation by the authorities.
In addition, do not pay out funds when you know that a
report has been made.
Further information on rules and standards
¥
Group Anti-Money Laundering & Counter-Terrorist
Financing Policy*
¥
Retail colleagues should follow the AML reporting process
in their shop operating procedures.
¥
Contact our AML or Legal & Compliance teams to access
handbooks, local policies and guidance for your particular
country or business.
* Only available to those on Oracle
Q
I’m aware that a customer is being investigated
for tax fraud and they are seeking to make a large
deposit into their Entain account.
A
This is a potentially suspicious transaction and
should be reported according to the process set out
in the Group Anti-Money Laundering & Counter-Terrorist
Financing Policy. Without further information, it’s possible
that the funds the customer is seeking to deposit may be
the proceeds from criminal conduct (i.e., tax fraud).
Examples
One type of money
laundering that occurs
frequently in practice is when
the proceeds of crime are
converted or disguised by being
spent or invested in legitimate
activities.”
¥
Always report any approach from the authorities for
information regarding money laundering, terrorist
financing or sanctions to the Legal or AML teams - do not
provide information to the authorities yourself.
¥
We must not do business with sanctioned or potentially
sanctioned parties. If you suspect that a party to a
proposed transaction may be sanctioned, report this to the
Legal & Compliance or AML team, or under the Group Anti-
Money Laundering & Counter-Terrorist Financing Policy.
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Q
At that same meeting, the attendees agreed to share
information on strategy for a specific market. As this
is an industry-wide decision, is it legitimate?
A
Not necessarily. While some information-sharing may
be legitimate (e.g., as to industry-wide responses to
proposed regulation), other information can be used to
coordinate actions and harm competition. Prior to sharing
any information, you should first speak to the Legal &
Compliance team.
Q
At a meeting of a gambling industry business
group, the attendees agreed that they’d work
together to block a competitor from entering a new
market. As this is an industry-wide decision, is it
legitimate?
A
No. Agreements between groups of competitors to
exclude others may be anti-competitive. Contact the
Legal & Compliance team for advice before taking any
further steps.
Examples
Competition
& anti-trust
We believe in free and fair competition.
We can only deliver value to our shareholders and other
stakeholders if our business is founded on principles of
integrity and fair play. Engaging in anti-competitive conduct is
the opposite of this fair play.
As such, we must not enter into formal or informal agreements
with our competitors, or share confidential information, in
a manner that could be anti-competitive. We must also not
abuse our market position to corner a market or disrupt trade.
Key points
¥
Keep information regarding prices, costs, commissions,
discounts, or rebates confidential and do not discuss them
with competitors.
¥
Make sure you do not enter into any oral or written
agreements with competitors to divide regions and
markets, coordinate bidding proposals, or fix prices or
returns for our products or services.
¥
Be aware of the potential effect that our own market power
may have on others.
Further information on rules and standards
¥ Group Competition/Antitrust Policy
¥ If you have any queries, contact the Legal &
Compliance team.
Entain plc
|
Our Code of Conduct
19
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Further information on rules and standards
¥
Group Insider Dealing & Inside Information Policy*
¥
Group Share Dealing Code**
* Only available to those on Oracle ** Not available for general distribution
Insider
dealing &
market abuse
We must not use inside information to
gainafinancialadvantageorotherwise
engage in market abuse.
Insider dealing refers to using non-public price-sensitive
information to gain an unfair advantage when buying or
selling shares in Entain or other publicly listed companies.
This could involve, for example, selling shares before company
losses are made public, buying shares before strong trading
figures are released, or buying shares before a deal is made
public. Such information is referred to as ‘inside information’ or
‘material non-public information’.
You must also be careful not to engage in other forms of
market abuse, including giving false or misleading signals, or
disseminating false or misleading information in relation to
Entain or other publicly listed companies.
Key points
¥
Do not buy, sell or deal in Entain shares or the shares
of any other company, or encourage others to do so, if
there is a reasonable chance you might have access to
inside information.
¥
Do not pass inside information to third parties without
appropriate authorisation.
¥
Do not create rumours or release false or misleading
information about Entain or any third parties.
¥
If you have access to inside information, you will need to
follow the procedure for obtaining ‘clearance to deal’ under
the Group Share Dealing Code.
Q
I’m aware that Entain is working on a lucrative
new product that has not yet been announced to
the market. I realise that I may, therefore, have inside
information and be restricted in my ability to buy or
sell Entain shares. However, my partner is considering
buying shares in Entain. I haven’t discussed the new
project with them. Do I need to take any further steps?
A
Yes. You should ask your partner not to buy shares
in Entain until you have spoken to the Legal &
Compliance team and, if relevant, followed the Group Share
Dealing Code. This will help determine if the information
is in fact inside information, bring added confidence that
you’ve not (even inadvertently) shared such information
with your partner and help avoid the perception that inside
dealing may have occurred.
Q
We know that one of our publicly listed service
providers is in financial difficulties, and this has
not yet been announced to the market. My father owns
shares in the service provider. As this information
relates to another company (and not Entain), am I free
to warn him to sell his shares before the news breaks?
A
No. Entain’s rules on insider dealing (which reflect
the requirements of applicable laws) prohibit using
non-public price-sensitive information to gain an unfair
advantage regardless of whether that information relates
to Entain or a third-party company. You should not provide
the warning to your father or otherwise discuss the matter
with him. If you need further assistance, please speak to
the Legal & Compliance team.
Examples
Insider dealing refers
to using non-public price-
sensitive information to gain
an unfair advantage when
buying or selling shares in
Entain or other publicly listed
companies.”
Entain plc
|
Our Code of Conduct
20
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
21
Tax evasion
Entain has zero tolerance for all tax
evasion and the facilitation of tax
evasion, in whatever form, anywhere in
the world.
‘Tax evasion’ occurs when a person knows they have an
obligation to pay tax, but deliberately and dishonestly does
not pay it in full (or when required). This may include a failure
to declare or report a tax liability properly or on time, or the
mischaracterisation of a relevant transaction.
Tax evasion is not the same as tax avoidance or tax planning
(which refers to taking steps, within the law, to minimise tax
payable or maximise tax relief claimed).
Anyone who deliberately and dishonestly assists a person in
their tax evasion will be ‘facilitating’ the tax evasion, whether
through an action (e.g., creating a false document) or an
omission (e.g., not issuing an invoice).
Key points
¥
Employees must not engage in any form of tax evasion
(whether relating to the UK or overseas).
¥
Employees must not encourage, assist, or otherwise
facilitate others to engage in any form of tax evasion
(whether relating to the UK or overseas).
Further information on rules and standards
¥ Group Anti-Facilitation of Tax Evasion Policy
¥ Anti-Bribery, Corruption & Tax Evasion
Procedural Framework**
¥ Anti-Bribery, Corruption & Tax Evasion Due
Di
ligence Procedure**
*
* Not available for general distribution
Q
A supplier has sent me an invoice for some services
we bought but it’s from a different company to the
one that provided the services for ‘tax reasons’.
I’ve checked and the company is part of its wider group.
As such, is this purely an internal issue for the supplier
and can I pay the invoice?
A
No. Unless there‘s a legitimate link between the
services and the different company, this may be an
attempt to evade or reduce taxes that would otherwise
be payable and, therefore, your actions in paying the
invoice may be facilitating tax evasion. You should raise
this immediately with the Legal & Compliance team (and
before taking any further action) for it to assess further or
otherwise report it under the Speak Out Policy.
Q
A customer has said that if I back-date an invoice,
we can get paid earlier. Can I agree to this?
A
No. You must ensure that all documents you produce
or oversee are fully accurate, complete, and not
misleading. Back-dating invoices can, under certain
circumstances, amount to fraud and / or facilitate tax
evasion. You should raise this with the Legal & Compliance
team (and before taking any further action) for it to assess
further or otherwise report it under the Speak Out Policy.
Tax evasion occurs when
a person knows they have
an obligation to pay tax, but
deliberately and dishonestly
does not pay it in full (or when
required).”
Examples
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc
|
Our Code of Conduct
22
Privacy, data
protection
& information
security
We are all responsible for protecting
personalandconfidentialdata.
Entain processes the personal data and confidential
information of its customers, employees and suppliers and
takes its obligations to ensure privacy and protection for this
data very seriously. Our aim is to ensure that information
remains confidential, is not misused or distributed unlawfully,
and is kept accurate and up to date in accordance with all
applicable data protection laws.
Fundamental to our data protection and information security
frameworks are the Group Data Protection Policy (which is
designed to ensure you understand how to treat and protect
personal data); and the Information Security Governing Policy
(which outlines how such information is protected in all its
forms and during all phases of its life cycle).
Key points
¥
Understand the information you are working with - is it
personal, non-personal, and/or confidential, and how can
this information be used and shared.
¥
Only share confidential information where lawful,
necessary, and appropriate, and only with those who need
it to do their job.
¥
Be transparent and clear with individuals whose
information is being processed what data we process, who
has access to it and why we process it.
¥
Minimise the amount of data being collected and use
anonymised or pseudonymised data where possible,
and ensure the data being processed is proportionate to
the purpose.
¥
Ensure Entain’s assets, resources, equipment, and data are
not compromised or inappropriately used.
¥
Think before you click. Do not open attachments or
links you are not expecting and report any suspicious
cyber activities or suspected data security incidents to
securityincidents@entaingroup.com.
¥
Only use authorised software and hardware and make sure
you comply with our IT procedures.
¥
Protect your password and data. Use strong passwords
and do not disclose them.
¥
Do not disclose personal data or confidential information
without prior approval.
¥
Make use of company-approved cloud storage sites (such
as Microsoft365).
¥
Follow internal instructions in connection with legal or
litigation holds that ask you to secure certain types of data
for specific periods of time.
Further information on rules and standards
¥
Group Data Protection Policy*
¥
Information Security Governing Policy*
¥
Group Data Retention Policy*
¥
Data Privacy space on Entain.me*
* Only available to those on Oracle
Q
I accidentally opened an email attachment that might
be suspicious. What should I do?
A
Despite our training and best efforts,
mistakes can happen. It is important that you
immediately report incidents such as these to
securityincidents@entaingroup.com.
Q
I’m based in the UK and have been asked by a
consultant that we’re using in the USA to send
them some customer data. As the consultant is
working for us and we have a contract with them, is it
okay for me to send the data or are there any further
steps required?
A
You are right to check as whenever we send personal
data overseas or to third parties, we should first
check whether we are permitted to do so under the
applicable data privacy law and, if so, whether there are
any special steps we need to take. Before sending the
data, please email dataprotection@entaingroup.com
for advice.
Examples
Entain takes its obligations
to ensure privacy and
protection for this data very
seriously.”
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Safeguarding
company
property
We are all responsible for protecting
company property and resources.
As part of our jobs, we’re all entrusted with Entain property
and resources. This can include intellectual property (“IP”)
(such as our innovations, brands, copyright, designs, trade
secrets, know-how and confidential information), physical
property (such as equipment, computers, and mobile phones)
and assets (such as money, expense accounts and access
to resources).
We must honour this trust by taking steps to protect such
property and resources and prevent unauthorised or
inappropriate use.
IP requires careful management and can easily be lost (e.g.
through improper disclosure or lapse of rights) or lose its
value (e.g. through competitors registering or using IP similar
to Entain IP). As such, we aim to properly identify, maintain,
protect, monitor, and enforce Entain’s IP, while also minimising
the risk of Entain infringing third party rights.
Key points
¥
Only use company property for business purposes and in a
way that is lawful and appropriate.
¥
Do not use, take, sell or give away any company property
without proper approval.
¥
When you’re developing new ideas, technology,
brand / product names or innovations, keep them
confidential and talk immediately to the IP Legal team
(IPteam@entaingroup.com) about how to protect them.
¥
Do not enter into any agreement to share Entain IP or to
create, license or transfer IP without first speaking with the
IP Legal team.
¥
Take appropriate steps to protect Entain’s IP when
communicating with third parties.
¥
Do not use the brands, technology, or IP of third parties
without proper authorisation.
¥
Consult immediately with the IP Legal team if you become
aware of third parties using our brands, technology or
other IP, or any allegations that Entain may have used the
brands, technology, or IP of third parties, in either case
without proper authorisation.
Q
My team wants to launch a new brand for our
business. Can we go ahead?
A
Before launching a new brand, please speak to
the IP Legal team. This is because appropriate
IP clearance searches will first need to be carried out
across all the territories in scope and, depending on the
brand and intended use, it may also be necessary to
make applications to protect the brand in the relevant
territories. This is the case even if the brand is already
being used by us in one territory, as there may be
restrictions on our ability to use the same brand in
another territory or the brand may not yet be protected
in all relevant territories.
Q
I’m working on a new marketing campaign.
We want to use a close-up image of a famous
footballer wearing his club’s shirt in the campaign.
Can we go ahead?
A
You’re right to check as image rights can be a
tricky legal subject that varies by country. As early
as possible, and before finalising the marketing
campaign, please speak to the IP Legal team who can
check to see if Entain is licensed to use the specific
image in question and advise you on any further steps
to be taken.
Examples
Further information on rules and standards
¥
Group Intellectual Property Policy**
** Not available for general distribution.
Entain plc
|
Our Code of Conduct
23
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
We all need to communicate
responsibly and in a way that is fair,
clear, and not misleading.
Managing our communications properly is an important
aspect of safeguarding Entain’s reputation and satisfying
regulatory compliance requirements. Engagement with
external parties (such as investors, the media, community
and government representatives, regulators, commercial
partners, and customers) should only be undertaken by those
colleagues who are specifically designated to do so.
Key points
¥
Do not communicate with external parties (whether orally
or in writing) unless you have specific approval to do so, or
it is part of your normal work duties.
¥
Refer any approach or query from external parties
to the relevant internal teams, such as the Corporate
Communications, Legal, Ethics & Compliance or Customer
Service teams.
¥
When communicating with external parties, ensure that
everything you say is fair, clear, and not misleading.
¥
Use good judgement and be accurate when commenting
on company matters on social media to avoid reputational
harm, the sharing of confidential or sensitive information, or
complaints from third parties.
Further information on rules and standards
¥ Ex
ternal Marketing Policy Statement
¥ If you have any queries, contact a member of the Corporate
Communications team.
Engagement with
external parties should only
be undertaken by those
colleagues who are specically
designated to do so.”
Examples
Q
I received an email from a journalist who wants to
ask me some questions about a recent incident. Can I
speak to them?
A
Before responding to the journalist, first speak with
the Corporate Communications team for guidance on
whether a response is appropriate, who should provide the
response and what the response should say.
Q
My team completed a very innovative project.
Can I tell everyone about it on social media?
A
While we at Entain celebrate our work achievements
and value innovation, it’s important that external
communications are consistent, strategic and take place at
the appropriate time. As such, don’t post on social media
or tell anyone about the project without prior approval from
the Corporate Communications team. This is especially the
case where the project may not yet be known publicly as
this could potentially be inside information (see the section
above on Insider Dealing & Market Abuse).
Entain plc
|
Our Code of Conduct
24
External communications
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Entain plc | Our Code of Conduct
25
Speak out
Ifyouthinktherehasbeen(ormightbe)abreach
of our Code of Conduct or you suspect any other
behaviour that might be illegal or unethical, please
speak out and let us know as soon as possible. We can
only investigate a possible breach if we know about it.
You do not need to be 100% sure of the facts, so long
as you have reasonable grounds for suspecting that
wrongdoinghastaken(ormighttake)place.
We know that it can take courage to do the right thing,
which is why we will treat reports sensitively and
confidentially.
We will never penalise somebody who raises
a genuine concern, even if it turns out that no
wrongdoing took place. Retaliation against someone
who reports will not be tolerated.
Click here to view the Speak Out Policy.
It does not matter whether you are an employee,
consultant or contractor: if you think that something is
not right, we want you to tell us about it. Here is how
you can let us know.
Q&A
Q
Are there things we shouldn’t use the
independent hotline (EQS) to report?
A
Yes. The hotline is only for serious issues
(e.g., breaches of this Code of Conduct)
that you do not feel comfortable reporting
internally. Our Grievance Procedure is the best
way to raise normal Human Resources-related
issues and workplace grievances.
Q
Will you keep my identity confidential if
I make a report?
A
You can raise a concern anonymously,
but even if you do not, we will keep your
identity confidential unless we cannot for legal
reasons (for example, if we have to give details
to the police or a court). It’s usually better to
say who you are though, as it makes concerns
easier to investigate if we can speak to you
in person.
Q
What happens if I was mistaken?
A
So long as your suspicions are genuine
and the report is not made maliciously,
we’ll never penalise you for raising a concern,
even if it turns out that we did not find any
evidence of wrongdoing.
Q
What if I think one of our partners or
suppliers is involved in wrongdoing?
A
You can use the Speak Out Policy to report
suspicions about third parties who provide
services to our company.
Your manager or HR
For employees, your first port of call should be your line
manager or your local Human Resources team. They will try to
resolve it or will pass it on to somebody else to look into.
Email us
There is a confidential mailbox (managed by the Audit
Committee) for anybody who wants to raise a concern.
Email details to:
whistleblowing@entaingroup.com
Independent hotline – EQS
There may be occasions when raising the matter internally
doesn’t feel like the right thing to do, so we have an
independent hotline provided by EQS that you can use.
You can contact the independent hotline, either through
their web portal using a computer or mobile device on
https://entaingroup.integrityline.com/
or by telephone on (0044) 3332423759 (UK).
Dedicated local phone numbers are also available for all
Entain’s major locations and can be found in the Speak Out
Policy. This service is available 24 hours a day 7 days per
week. EQS enables you to easily
raise and discuss your concern in
your choice of fifteen languages, by
phone or online. Please tell them that
your call relates to Entain, and they
will then ask you for which business
you work within Entain. You do not
have to give your name if you feel
uncomfortable doing so.
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
Appendix
Policies and Procedures supporting this Code of Conduct
Topic Links
Working with each other Environmental Policy Statement
Health, Safety, Wellbeing & Workplace Policy Statement
Employee Assistance Programme (EAP) for UK employees only.
Supporting our customers
Global Safer
Gambling Statement
External Marketing Policy Statement
Ask your line manager or the Legal & Compliance team for Safer Gambling and
AML policies that apply to your role, local market or business.
Working with suppliers
Supplier Code of Conduct
Procurement Policy*
Global Payment Processing Policy*
Anti-Bribery, Corruption & Tax Evasion Due Diligence Procedure**
Modern slavery & human rights
Group Modern Slavery & Human Rights Policy
Supplier Code of Conduct
Gifts, hospitality & donations
Group Gifts, Hospitality & Donations Policy
Group Anti-Bribery & Corruption Policy
Conflicts of interest
Group Conflict of Interest Policy
Fraud
Group Anti-Facilitation of Tax Evasion Policy
Group Conflict of Interest Policy
Global
Payment Processing Policy*
Procurement Policy*
Group Insider Dealing & Inside Information Policy*
Bribery & corruption
Group Anti-Bribery & Corruption Policy
Anti-Bribery, Corruption & Tax Evasion Procedural Framework**
Anti-Bribery, Corruption & Tax Evasion Due Diligence Procedure**
Group Gifts, Hospitality & Donations Policy
* Only available to those on Oracle ** Not available for general distribution
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26
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Topic Links
Anti-Money laundering,
counter-terrorist financing & sanctions
Group Anti-Money Laundering & Counter-Terrorist Financing Policy*
Retail colleagues should follow the AML reporting process in their shop
operating procedures.
Contact our AML or Legal & Compliance teams to access handbooks, local
policies and guidance for your particular country or business.
Competition & anti-trust
Group Competition/Antitrust Policy
If you have any queries, contact a member of the Legal & Compliance team.
Insider dealing & market abuse
Group Insider Dealing & Inside Information Policy*
Group Share Dealing Policy**
Tax evasion
Group Anti-Facilitation of Tax Evasion Policy
Anti-Bribery, Corruption & Tax Evasion Procedural Framework**
Anti-Bribery, Corruption & Tax Evasion Due Diligence Procedure**
Privacy, data protection &
information security
Group Data Protection Policy*
Information Security Governing Policy*
Group Data Retention Policy*
Data Privacy space on Entain.me*
Safeguarding company property Group Intellectual Property Policy**
External communications
External Communications Policy
If you have any queries, contact a member of the Corporate
Communications team.
* Only available to those on Oracle ** Not available for general distribution
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Our Code of Conduct
27
A message from our CEO Our values Our responsibilities Standards of behaviour Speak Out
