CODE OF

BUSINESS
CONDUCT
AND ETHICS

Effective January 1, 2019

2 A MESSAGE FROM OUR CHAIRMAN CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 3

A MESSAGE FROM CONTENTS

OUR CHAIRMAN
The Code is a tool No code or policy can spell out the laws and rules of
appropriate conduct and ethical behavior for every business
A Message from Our Chairman 2 Principle 2: Doing Business
Ethically and Legally 14
Principle 4: Enhancing
Our Communities 30
for you; read it, situation. This Code is intended to provide each of us with Doing What’s Right for Individuals, Complying with Gaming Laws Participating in Civic and
refer to it, apply it. guiding principles on how to apply our own common sense,
good judgment, and conscience and to assist us in our work
the Company, Investors, and
Our Community 5
and Regulations 14 Government Activities 30
on behalf of the Company. Remember, we must not only Promoting Responsible Gaming 15 Conducting Business Sustainably 31
Doing Business the Right Way 5
follow these principles when it is easy, but when it is hard to Preventing Bribery
do so. Making the right decision, even when there is pressure We Follow the Code 6 and Corruption 16 Making Sure the Code Works 32
As Chairman of the Board of Directors and Chief Executive or an incentive to do otherwise, protects the Company and Our Global Obligations 6 Engaging in Fair Competition 17 The Global Compliance
Officer of Las Vegas Sands Corp. (“LVS”) and Sands China our hard-earned reputation. Your Responsibilities as a Department 32
Preventing Money Laundering 18
Ltd. (“SCL”), I am pleased to introduce our updated Code of Team Member 7
Treating Vendors and Other Resources in the Company 32
Business Conduct and Ethics (“Code”). This updated Code It is crucial that you report any allegations of violation of the
Special Responsibilities for Suppliers Fairly 19 Seeking Guidance 32
reflects how Las Vegas Sands does business ethics differently. Code to your supervisors, the Compliance Department, and/
Leaders and Managers 7
It embodies our renewed and steadfast commitment to the or the Ethics Hotline as soon as you are made aware of them. Adhering to Global Trade Laws 20 How We Investigate Misconduct 32
highest standards of professional conduct in every way and LVS has a strict anti-retaliation policy to protect you when We Do Not Tolerate Retaliation 7
Disciplinary Action 33
every place we do business. you report concerns. Vigilant Team Members and affiliated Principle 3: Protecting Our Your Obligation to Help 34
Covered Persons are our best line of defense in maintaining Principle 1: Respect for Individuals 8 Company and Investors 22
Our processes and personnel are and will continue to be our reputation and protecting the business, its customers, Government Investigations 34
Keeping Our Properties Safe 8 Protecting Company Resources 22
the best in every aspect of our business – including, and and shareholders. Waivers and Amendments 34
Preventing Discrimination Maintaining Accurate Books
especially, in the ethical performance of our jobs. We are This Code Is Not a Contract 34
and Harassment 9 and Records 23
judged not only by our conduct, but by the appearance of our Compliance with this Code is a standard of conduct to which
Encouraging Diversity Acknowledgment 34
conduct. At the most fundamental level, the Company strives we must hold ourselves and each other. Each of us – every Avoiding Conflicts of Interest 24
to always do the right thing and we expect Team Members to director, officer, Team Member, and business partner – will and Inclusion 10
Safeguarding Company
do the same. We do the right thing by respecting individuals. be judged by how we incorporate these principles into our Stopping Human Trafficking 11 Who to Contact 35
Confidential Information
We do business ethically and legally. We protect our Company conduct, and each manager will be judged by how they Protecting Guest and Team and Intellectual Property 26
and investors and we enhance our communities. promote the ethical principles contained in this Code with Member Privacy 12 Respecting Trade Secrets
those they manage. A reputation built over years can be lost
of Others 27
The Code clearly communicates standards and expectations through a single careless, unethical act. We hope and expect
that every Team Member is charged with knowing and that through this updated Code of Business Conduct and Complying with Securities
abiding by. The updated Code places greater emphasis on, Ethics, we will help nurture and sustain this tradition of trust. Trading Laws 28
and introduces, issues that have attracted increased attention Properly Communicating
within the industry, in public discussion, or among regulators, Sincerely yours, Outside the Company 29
such as data privacy, social media usage, sustainability, and Safely Using Social Media 29
corporate social responsibility. The Code is a tool for you; read SHELDON G. ADELSON
it, refer to it, apply it. CHAIRMAN OF THE BOARD AND
CHIEF EXECUTIVE OFFICER
4 D O I N G W H AT ’S R I G H T CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 5

DOING WHAT’S RIGHT

FOR INDIVIDUALS, THE
COMPANY, INVESTORS,
AND OUR COMMUNITY
Doing Business the Right Way 4. We enhance our communities
The Company has properties in locations around the
At Las Vegas Sands, we believe in providing unmatched
globe. Our interactions with the communities in which we
guest service. This concept runs through everything we do,
work provide opportunities to improve the world around
from how we design our hotels to the extra effort our Team
us. Whether working with local governments, or making
Members provide to a guest in need. But just as importantly,
sure we act as stewards of the environment we live in,
we always act with integrity, meeting our legal and ethical
we look to make our communities better places.
duties. In short, whatever we do, we do it the right way. This
means in carrying out our mission to provide our guests with
Doing what is right is the most important job a Team Member
the very best experience, we keep four principles of ethical
has. While it can sometimes be tempting to disregard this
conduct in mind at all times:
idea in an effort to meet an executive’s urgent request, get
a job done quickly, or close a deal, this is not a risk we take.
1. We respect individuals
No guest, no contract, no deal is more important than the
Whether Team Members, guests, suppliers, or members of
reputation and future of the Company.
the community, we treat each individual with whom we come
into contact with the utmost respect. We strive to make sure
they are safe and free from discrimination or harassment.

2. We do business ethically and legally

The Guiding Principles
We follow the letter and the spirit of all laws the Company
is obligated to follow. We are aware of our global obligations.
We act with integrity in every action we take on behalf
of the Company.
WE RESPECT WE PROTECT OUR
3. We protect our Company and our investors INDIVIDUALS COMPANY AND
The continued growth of the Company benefits our OUR INVESTORS
investors and our Team Members. Our actions are designed
to safeguard the assets and reputation of the Company.

WE DO BUSINESS WE ENHANCE OUR

E T H I C A L LY A N D COMMUNITIES
L E G A L LY
6 D O I N G W H AT ’S R I G H T CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 7

We Follow the Code As a public company and business operating Our Global Obligations Your Responsibilities Special Responsibilities
This Code provides you with a high-level
under licenses obtained in the various
As an international business, the Company is as a Team Member for Leaders and Managers Example
jurisdictions in which we operate, we must
overview of the core principles that impacted by the laws and business customs John manages six Team Members in
be mindful of the many important laws We rely on each other to do the right thing. Making sure we comply with the Code is the
govern our way of doing business, as well of the countries in which we operate. In the Safety Department. One of them,
and regulations governing our conduct. This means seeking help when you have a responsibility of every Team Member, but
as links to the more detailed policies and some cases, the law of a particular country Sarah, filed a report claiming that John
Compliance with both the letter and spirit question or concern. As listed throughout managers, supervisors, and our Company
procedures our Team Members and other may appear to require us to take actions that had been passing certain equipment
of all laws, rules, and regulations applying this Code, there are many ways for you to leaders have a special responsibility for
Covered Persons are expected to know may be contrary to this Code. If you believe as certified for use even though a full
to the Company’s business, including the seek guidance or report a concern – choose ensuring the Code and Company policies
and follow. This Code is intended to help a conflict exists between the Code and the inspection had not been completed.
requirements of any organization or entity the way most comfortable for you. are followed. Every manager and supervisor
all of us detect and prevent violations of laws of a particular country, you should It turned out that John had gotten
regulating the Company, is critical to the is responsible for communicating Company
law and corporate policy and to promote bring the conflict to the attention of the approval for this from his manager but
Company’s reputation and continued Report violations or concerns. If you discover policies to his or her Team Members,
individual accountability. Chief Compliance Officer for your region, the did not tell his staff. After the report
success. You must respect and obey the laws what you in good faith believe are actions including those dealing with legal and
Global Chief Compliance Officer, or Legal. was resolved, John held his annual
of the cities, states, and countries in which in violation of this Code, or are actions of a ethical behavior. Managers and supervisors
The Code applies to all directors, officers – summer open house at his home. As in
we operate and avoid even the appearance questionable, fraudulent, or illegal nature, are also responsible for maintaining a work
including our principal executive officer, In some countries, business practices are previous years, most of the guests were
of impropriety. you must report the matter immediately in environment where constructive, candid,
principal financial officer, and principal based on less stringent laws or different Team Members, including everyone
accordance with the Company’s Reporting and open discussion is encouraged and
accounting officer – Team Members, business expectations and customs. For in his department. However, this year
You are not expected to navigate these laws and Non-Retaliation Policy. Making a report expected, without fear of retaliation. But
consultants, vendors, and agents of the business dealings in such countries, the Code he did not invite Sarah because of her
and expectations alone. The Company has in good faith does not mean your suspicions most importantly, managers, supervisors,
Company, regardless of where they perform should continue to be followed and any complaint, even though she had been
numerous resources to provide guidance and have to be correct or proven. It just requires and Company leaders should be role models
their work for the Company. All of these are requests for variances should be directed to invited in the past.
a variety of ways to voice a concern, listed in that you provide truthful and accurate for their teams.
referred to as “Covered Persons,” and when the Global Chief Compliance Officer.
the “Making Sure the Code Works” section of information if you have a reasonable basis to
this code references “we” or “you” it includes Q : I S T H I S R E TA L I AT I O N ?
this document. believe the reportable behavior occurred or
all Covered Persons. When the Code talks
is going to occur. Reports made out of spite
We Do Not
about the Company, it includes Las Vegas A: Yes. John’s party was held off-
Sands Corp. (“LVS”), and/or its affiliates,
or those which intentionally include false Tolerate Retaliation property and may have been personal
information are not good faith reports. To
including Sands China Ltd. (“SCL”), Marina Bay The Company takes all good faith reports in his mind. But because the guest
the extent permitted by law, you may choose
Sands Pte. Ltd. (“MBS”), and/or their affiliates. seriously. Retaliation against a Team Member list was primarily Team Members, and
to remain anonymous in reporting any
making a good faith report or complaint, many of the attendees were there as
possible violation – a 24 hour/7 days a week
As you read the Code and related materials, seeking advice or guidance about a matter co-workers, not personal friends, not
Ethics Hotline is available for web and phone
keep in mind compliance and integrity is an under the Code, or cooperating with an inviting Sarah can be seen as treating
reports, available at lvscethics.com
element of each of our jobs and an essential investigation of a potential violation will NOT her differently than her co-workers.
or 1.888.469.1536.
part of our commitment to leading in all be tolerated under any circumstance. Any As the only difference this year was
aspects of our business. The LVS and SCL person involved in such retaliation violates Sarah’s report about John, a reasonable
Boards of Directors and MBS management the Code and is subject to discipline up to person could see this as an effort to
have made clear that compliance is also a and including termination. retaliate against Sarah.
measurement of our performance and the
Company has adopted a Clawback Policy, Retaliation can take many forms. It can
consistent with applicable law, to reinforce include a manager reducing pay and
its importance. Doing the right thing at all benefits, denying promotion, or assignment
times is a standard to which we must hold to less desirable shifts. It can also be
ourselves and each other. more subtle; treating someone differently
simply because they filed a report or
complaint is also retaliation.
8 PRINCIPLE 1: RESPECT FOR INDIVIDUALS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 9

PRINCIPLE 1 PREVENTING DISCRIMINATION

RESPECT FOR AND HARASSMENT

INDIVIDUALS Doing the Right Thing

We are committed to providing a
HOW We Do It
• Promulgating and enforcing
Q&A
Q: IS SEXUAL HARASSMENT
workplace free from discrimination
We conduct our business in a way that shows and harassment.
our Preventing Discrimination
and Harassment Policy.
L I M I T E D TO U N WA N T E D
P H YS I C A L CO N TA C T ?
respect for our Team Members and guests • Requiring all Team Members to
complete a sexual harassment A: No! Sexual harassment may consist
WHY We Do It awareness training program. of verbal, visual, or physical conduct of
Las Vegas Sands seeks to foster a workplace • Training our Team Members to a sexual nature that is unwelcome or
where Team Members are treated fairly identify and prevent workplace makes someone feel uncomfortable. It
and are able to reach their full potential discrimination and harassment. can take many forms, including sexual
and contribute to the Company’s success. • Having a zero-tolerance approach advances or unwelcome demands

KEEPING OUR PROPERTIES SAFE Team Members should expect a workplace

free from harassment and disrespectful
to harassment and discrimination
within our workplace.
for dates; sexually oriented jokes,
pictures, or text messages; or the
conduct. Preventing discrimination and • Basing all employment decisions display of sexually suggestive images
harassment is not only the right thing to do, regarding Team Members on merit, or pornography.
Doing the Right Thing HOW We Do It Learn More it is good business as well. The productivity qualifications, and job-related
We operate in a way that ensures • Maintaining and enforcing a • Team Member Handbook and morale of our Team Members suffer characteristics except as required
our Team Members’ and guests’ Written Workplace Safety Program. • Written Workplace Safety Program when they are subjected to unwelcome under local law or local government
safety when on our property. • Making the prevention of occupational • Environmental Responsibility Policy conduct in the workplace. All Team Members policy or expectations.
accidents and illness a responsibility • Project Protect should be treated fairly and with respect • Providing Team Members multiple
of every supervisor and manager. and protected from all forms of harassment channels to report discrimination
WHY We Do It • Adhering to an Environmental and discrimination. or harassment.
Any time a Team Member or guest steps onto Responsibility Policy.
WHAT Can I Do?
our property, they should feel the Company • Complying with all public health If you see a safety hazard, report it to your Harassment is unwelcome or abusive
is doing all it can to keep them safe. We know and environmental laws pertaining supervisor right away. You may help prevent conduct based on race, color, religion,
Learn More
they expect to be protected from harm while to our operations. an accident or injury. If an unsafe condition sex, pregnancy, national origin, sexual • Preventing Discrimination
on our property and we work hard to meet • Maintaining an open dialogue with persists, you can report it to the Compliance orientation, gender identity, age, disability, and Harassment Policy
these expectations. We care about our Team our local communities on any hazards or Facilities Departments through any of the or genetic information. • Project Protect
Members and want to ensure everyone has a posed by our operations. channels discussed at the end of this Code. • U.S. Equal Employment
safe and healthy working environment. • Working with government authorities, Discrimination is the unjust or prejudicial Opportunity Commission:
industry groups, and the public to treatment of an individual based on race, https://www.eeoc.gov
promote awareness of and develop color, religion, sex, pregnancy, national • Macao Labor Department:
appropriate responses to any hazards origin, sexual orientation, gender identity, https://www.dsal.gov.mo/en/standard/
related to our operations. age, disability, or genetic information. index.html
• Providing state-of-the-art security
for our properties.
10 PRINCIPLE 1: RESPECT FOR INDIVIDUALS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 11

ENCOURAGING DIVERSITY AND INCLUSION STOPPING HUMAN TRAFFICKING

Doing the Right Thing HOW We Do It Learn More Doing the Right Thing HOW We Do It Learn More
We are committed to creating a culture • Recruiting, training, and developing • S ands Cares: We work to prevent all forms of • Promulgating and enforcing our • Anti-Human Trafficking Policy
of diversity, inclusion, and belonging individuals of all experiences, ages, http://www.sands.com/sands-cares/ human trafficking on our properties Anti-Human Trafficking Policy. • Project Protect
for our Team Members. cultural and racial backgrounds, and people.html and in our supply chain. • Taking a zero-tolerance approach to • Supplier Code of Conduct
religious beliefs. • Team Member Handbook human trafficking.
• Valuing and showing respect for the • Project Protect • Requiring suppliers to comply with our
WHY We Do It unique cultural backgrounds and diverse • Contact Human Resources
WHY We Do It Anti-Human Trafficking Policy and Supplier
WHAT Can I Do?
At Las Vegas Sands, we believe our work experiences of our Team Members. Human trafficking is a crime involving the Code of Conduct. Be alert. Team Members who are in frequent
culture is enhanced and our business is most • Maintaining membership in and support buying and selling of people for sexual • Ensuring our global procurement team contact with our guests are in the best
successful when we embrace the unique of groups and programs that encourage
DID You Know? services or forced labor. The hospitality communicates these policies to suppliers. position to observe potentially troubling
experiences and diverse perspectives of and promote various diversity and The Company employs over 50,000 Team industry is not immune to this problem. • Training our Team Members to identify and behavior. When you see a concerning
our Team Members. This means showing an inclusion initiatives. Members at 10 properties and locations Indeed, traffickers often take advantage of respond appropriately to instances of sex situation, evaluate it for signs of human
understanding of and respect for all Team throughout the world. Our Team Members the privacy and anonymity hotels offer. Sex trafficking on our properties. trafficking. If sufficient indicators are present,
Members’ gender, race, ethnicity, sexual collectively speak more than 20 languages. trafficking in hotel settings harms the victims • Engaging with local law enforcement for alert your supervisor immediately. They
orientation, disability, religion, and age, as and threatens the safety and well-being of specialized training. will assess the situation and notify security
well as their unique cultural backgrounds, guests, Team Members, and the community. • Partnering with local government if appropriate. For everyone’s safety, Team
experiences, opinions, and ideas. Our Likewise, labor trafficking threatens supply and non-profit organizations on anti- Members should not take direct action
properties serve guests from around the chain stability and does economic harm and trafficking efforts. on their own.
world, and having Team Members who reputational damage to the Company. We • Conducting third party audits of suppliers
reflect this diversity allows us to better serve proactively work to stop the exploitation to ensure fair treatment of workers.
our guests. It also creates a more successful of vulnerable people and remain vigilant • Prohibiting the use of recruiters that
work environment for Team Members. to the presence of human trafficking in charge employees fees (unless mandatory
our business. by local law) or impose inappropriate
conditions of hire or employment.
12 PRINCIPLE 1: RESPECT FOR INDIVIDUALS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 13

PROTECTING GUEST
AND TEAM MEMBER PRIVACY
Doing the Right Thing Learn More
We are committed to protecting the • Global Privacy Policy:
privacy and personal information of https://www.sands.com/privacy-
our guests and Team Members. policy.html
• Singapore: MBS Personal Data Protection
Policy Manual
WHY We Do It • Macao: Personal Data Guidelines
In the course of our business, we collect and
use information from our guests and Team
Members to provide world-class products, Q&A
services, and experiences. Guests and Team
Q : I H AV E S O M E PA P E R S
Members trust the Company to safeguard
T H AT I N C L U D E A L O T O F
and protect this information and we are
TEAM MEMBER PERSONAL
committed to doing so. In addition, many
D ATA A N D S A L A R Y D E TA I L S
of the places where we operate have laws
T H AT I N O L O N G E R N E E D.
surrounding data privacy and protection, and
CAN I JUST THROW THESE
it is our responsibility to adhere to those laws.
PA P E R S AW AY I N T H E
GENER AL REC YCLING BIN?
HOW We Do It
A: No! Records containing personal
• Issuing a Global Privacy Policy and training
data need to be disposed of securely
all Team Members to take reasonable
(i.e., by shredding or using a secure
measures to prevent unauthorized
document disposal facility).
access to and disclosure of our guests’
personal information.
• Disciplining Team Members who
violate the privacy of our guests and/or
Team Members.
• Securing information maintained in
electronic form on systems protected by
best-in-class industry security measures.
14 P R I N C I P L E 2 : D O I N G B U S I N E S S E T H I C A L LY A N D L E G A L LY CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 15

PRINCIPLE 2 PROMOTING RESPONSIBLE GAMING

DOING BUSINESS Doing the Right Thing • Establishing a fun and safe environment that • Marina Bay Sands:

ETHICALLY AND LEGALLY

promotes responsible gaming in our resorts https://www.marinabaysands.com/
We are a leader in making responsible and raising awareness of the potential effects company-information/responsible-
gaming a top priority. associated with problem gambling. gambling.html
• Developing robust programs and initiatives • Sands China Ltd.:
In everything we do, we follow the law and act WHY We Do It that provide information to increase guest https://www.sandschina.com/community-

in a responsible and ethical manner Problem gambling affects approximately

awareness of responsible gaming and the
support that is available.
affairs/responsible-gaming.html
• Project Protect
1% of U.S. adults, and we take responsible • Partnering with leading experts to
gaming very seriously. Our goal is to remain develop a specialized Responsible Gaming
the industry leader in responsible gaming Ambassador program to train Team
HOW Can I Help?
and to ensure that the necessary community Members how to respond to our guests’ • Familiarize yourself with all Responsible
resources are available both for guests who needs and refer them to appropriate Gaming program materials and services
seek assistance and the organizations that support services. and know how to direct guests to
help provide care and support. • Working with local governments and resources addressing the issue.
COMPLYING WITH GAMING LAWS AND REGULATIONS service providers in every community in • Know when and how to call upon a
which we operate. Responsible Gaming Ambassador to assist
HOW We Do It a guest in need.
Doing the Right Thing HOW We Do It Learn More • Ensuring that we not only comply with,
Learn More • Become a Responsible Gaming
but well exceed all responsible gaming Ambassador by attending the
We comply with gaming laws and • Complying with all rules and regulations • U.S.: 702.607.4626
government regulations. • Las Vegas Sands Corp.: annual training.
regulations in every jurisdiction in set forth by gaming regulators in the • Singapore:
• Training Team Members how to recognize https://www.sandscasino.com/global/
which we conduct business. regions in which we operate. [email protected]
and respond to guests who may exhibit responsible-gaming.html
• Maintaining a successful compliance • Macao: +853 811 82273
signs of or seek help for problematic • The Venetian and The Palazzo:
program focusing on gaming
WHY We Do It regulatory matters.
gaming behavior. https://www.venetian.com/casino/
responsible-gaming.html
Gaming is a highly regulated business. All of • Creating gaming-related policies,
our properties operate pursuant to specially procedures, and internal controls, and
Who Are Our
granted licenses and/or concessions. publicizing them where appropriate. Gaming Regulators?
Accordingly, we must be cognizant of the • Cooperating with regulators in the
Nevada
laws, rules, and regulations governing jurisdictions in which we operate.
Nevada Gaming Control Board
our gaming activities. We also have a • Training Team Members on casino-related
responsibility to ensure our gaming activity is operations and the rules applying to them.
Pennsylvania
fair to our patrons.
Pennsylvania Gaming Control Board

Singapore
Casino Regulatory Authority

Macao
 aming Inspection and
G
Coordination Bureau
16 P R I N C I P L E 2 : D O I N G B U S I N E S S E T H I C A L LY A N D L E G A L LY CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 17

PREVENTING BRIBERY AND CORRUPTION ENGAGING IN FAIR COMPETITION

Doing the Right Thing Key Concepts Doing the Right Thing
Neither we nor anyone acting on We are committed to winning business
• Bribery is prohibited: No Covered
our behalf will ever pay, offer to pay, fairly and through free and open
Person or anyone acting on behalf of
receive, or solicit any bribe, kickback, competition in the marketplace.
the Company may ever pay, promise,
or other payment, whether cash or
offer to pay, or approve payment
anything of value, in order to do
business, gain a business advantage,
of money or anything of value to WHY We Do It
any Government Official, directly
or secure a license or permit. There are a variety of laws we operate under
or indirectly, in order to influence
that promote vigorous competition in the
that official to act or not act in their
marketplace and protect consumers. These
WHY We Do It official capacity.
laws vary throughout the world, but they
• “Anything of value”: Includes
In every jurisdiction where we operate, the always prohibit companies from sharing
cash, cash equivalents (such as gift
law prohibits paying a bribe or kickback to information that could reduce competition.
cards), accommodations, meals,
government officials and, in most cases, to Violations carry serious civil and criminal
theater tickets, employment, travel,
an employee of a private company. When penalties, as well as the risk of private civil
and even such things as charitable
someone demands a bribe in connection actions. We do not need to seek an improper
• Reviewing how we interact with donations or sponsorships that may
with their job, they violate their duty to act advantage; we outperform our competition
Government Officials and Politically enhance an official’s reputation.
in the best interest of the public or their legally and ethically.
Exposed Persons on our property, • Politically Exposed Person (“PEP”):
employer. The person paying the bribe
including making sure we extend An individual (including an
is undermining fair competition and, if
discovered, they endanger their company’s
complimentaries only in accordance with immediate family member or a HOW We Do It
our written policies. close associate) who is or has been
business and reputation. For example, as a • Promulgating, enforcing, and training
• Complying with our Charitable entrusted with any prominent
casino, we could lose our license to operate relevant Team Members on our
Contributions and Sponsorship public function in the United States,
if we were found to have paid or offered to Competition Policy.
Policy requiring management and or in any other country, or an
pay a bribe. The law imposes severe criminal • Never discussing or entering into
Compliance Department approval. international organization (like the
and civil penalties on both the companies agreements with competitors about
• Conducting extensive due diligence on United Nations or FIFA).
involved and individual employees pricing, division of customers, costs, or any
third parties with whom we do business. • Government Official: Includes
responsible for the misconduct. other topics that could limit competition
• Requiring our suppliers to act legally and government officials in the United
or harm consumers.
ethically in accordance with our Supplier States (whether at the federal,
• Respecting competitive bidding processes
HOW We Do It Code of Conduct. state, or local level) and non-U.S.
when seeking new or continuing business.
government officials (including
• Enforcing a strict Anti-Corruption Policy • Using only legal methods to gather
employees of state-owned
that prohibits any bribes or kickbacks, Learn More enterprises, political parties, and
information about our competitors.
whether to a Government Official or
• Anti-Corruption Policy international organizations). It also
anyone else with whom we do business.
• Refusing to pay “grease” or make
• Charitable Contributions and includes almost all employees of Learn More
Sponsorship Policy state-owned enterprises.
“facilitation” payments to speed up • Competition Policy
• Third Party Travel, Gifts &
Government Officials in carrying out
Entertainment Policy
• Confidential Information Policy Doing the Right Thing in Action
their duties.
• Conflict of Interest Policy If you are in a situation where a room if possible. Inform the Compliance
• Limiting the gifts and entertainment
• Politically Exposed Person Standard competitor starts discussing these Department of what happened as soon
we may accept from or give to other
Operating Procedure prohibited topics, politely excuse yourself as possible so it can document the action
Covered Persons or entities with whom
• Complimentary Policy from the conversation and leave the you took to avoid the conversation.
we do business.
• Contracting Overview Policy
• Training Team Members on our anti-
• Supplier Code of Conduct
corruption program.
18 P R I N C I P L E 2 : D O I N G B U S I N E S S E T H I C A L LY A N D L E G A L LY CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 19

PREVENTING MONEY LAUNDERING

• Promoting and maintaining an open line • A guest providing insufficient or
Doing the Right Thing of communication between departments. suspicious information, such as
We prevent money laundering • Knowing our guests and understanding conflicting identification.
and terrorist financing activities their sources of funds. • A guest chip sharing with other guests
by complying with all laws and • Filing all required reports and partnering without justification or allowing other
regulations and enforcing a strict Anti- with local law enforcement and guests to play under their membership card.
Money Laundering (“AML”) Program. government agencies.
• Recognizing indicators (“red flags”)
of suspicious activities and transactions
Learn More
WHY We Do It in a casino. • Global AML Policy
Money laundering has significant economic, • Stopping the play of any guest we believe • Internal Controls:
security, and social consequences. Money is involved in money laundering activity. –– Marina Bay Sands
laundering takes several forms, including –– Sands China Limited
(1) hiding the proceeds of illegal activities, –– Venetian Casino Resorts
(2) making the sources of illegal funds appear
WHAT Does Money
legitimate, or (3) spending “dirty money,” Laundering Look Like?
such as by gambling or shopping. It also
Every case is unique, but one example would
Key Definitions
includes terrorist financing, the process
be a guest who arrives at a gaming table with • Currency Transaction Report
by which illegal terrorist organizations
large amounts of small bills derived from (“CTR”/”LSTR”): A CTR (called an LSTR
channel funds to their operations. A variety
drug dealing. The guest converts the cash in Macao) is a report we must file
of criminal enterprises, including those
into chips, plays for only a few minutes, and with the government when a person
dealing dangerous drugs or engaging in
bets only a very small portion of their stack. or their agent conducts a single or
human trafficking, rely on money laundering
The guest then heads to the cage where they multiple currency transactions in
to process their illegal profits. At Las Vegas
Sands, our casinos assist our governments in
ask for their money in larger denominations. excess of a designated amount in a TREATING VENDORS AND SUPPLIERS FAIRLY
They are paid and leave the premises. The day.
combating money laundering and terrorist
guest can now claim the cash as “winnings” • Suspicious Activity or Transactions
financing. We focus on preventing, detecting,
and reporting suspicious activities and
and although they may have to pay taxes on Report (“SAR”/“STR”): An SAR (in Doing the Right Thing HOW We Do It Learn More
it, they can show it as “legitimate” income. the U.S.) or STR (in other jurisdictions)
transactions that may take place on We maintain objective and fair • Maintaining a transparent, open, and fair • Contracting Overview Policy
is a report we must file with the
our properties. business relationships with suppliers. purchasing and procurement process • Procurement Policies
government concerning suspicious
WHAT Are the Red Flags? or potentially suspicious activities
governed by our Contracting Overview • Third Party Due Diligence Standard
and Procurement Policies. Operating Procedure
HOW We Do It Indicators of potentially suspicious activities and transactions that take place at or WHY We Do It • Reviewing each supplier and vendor to • Sourcing Procedures
and transactions you may encounter. Here involve our properties.
• Adopting a Global AML policy. Our guests expect the best, and we expect make sure they are operating according to • Conflict of Interest Policy
are a few examples: • Chip Walk: A patron may have “walked
• Ensuring that each property strictly to get the best through objective and fair the legal and ethical standards we expect.
• A guest’s reluctance to proceed with a with chips” when they appear to have
adheres to all applicable AML and relationships with our vendors and suppliers. • Avoiding conflicts of interest in our
transaction after being told it must be left the casino without redeeming the
Counter Financing of Terrorism laws
reported to the government. chips in their possession and did not
We engage with ethical and trustworthy procurement process so decisions Key Information
and regulations. suppliers who will provide the high-quality are made using objective and
• A guest refusing to provide identification return within a reasonable time frame. The Company uses Ariba, a
• Ensuring each property is following a strict goods and services our guests expect and independent judgment.
or identifying information. • Structuring: The act of breaking purchasing, contract, and payment
program of internal controls to prevent deserve. We select partners who not only
• Large transactions with minimal down large transactions into smaller management software system to
money laundering. provide the best value for our Company but
gaming activity. transactions in an attempt to avoid ensure products and services are
• Providing AML training tailored to safeguard our reputation for excellence.
the filing of a CTR. procured and paid for pursuant to
appropriate Team Members’ duties
our policies and procedures.
and responsibilities.
20 P R I N C I P L E 2 : D O I N G B U S I N E S S E T H I C A L LY A N D L E G A L LY CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 21

ADHERING TO GLOBAL TRADE LAWS

Doing the Right Thing Learn More
We follow all applicable laws and • U.S. Economic Sanctions Compliance
regulations that govern global trade Commitment and Policy Statement
and ensure compliance with all trade
sanctions programs in the countries
where we do business.
Key Concepts
• U.S. Department of Treasury’s
WHY We Do It Office of Foreign Assets Control
The Company conducts business all over (“OFAC”): OFAC is responsible
the world and is subject to various trade for administering and enforcing
laws. These laws prohibit or restrict our economic sanctions programs,
ability to engage in business activities with primarily against countries
certain countries and individuals; failure and individuals.
to follow these restrictions can give rise to • Country-Based Sanctions: Country-
serious penalties. It is our responsibility to be based sanctions prohibit any and
familiar and comply with all applicable laws, all transactions or other dealings
regulations, and restrictions involving our involving the sanctioned countries,
trade activities. or nationals and residents of
such countries.
• Specially Designated Nationals
HOW We Do It (“SDN”): An SDN is an individual
• Adhering to the Company’s U.S. Economic or an entity specifically designated
Sanctions Compliance Commitment and by OFAC as a threat to U.S. national
Policy Statement. security and other U.S. foreign
• Training our Team Members on the policy goals.
Company’s sanctions compliance policies
and procedures.
• Maintaining accurate records of all
transact­ions and audits for at least a
five-year period.
• Screening all guests and third parties
involved in transactions.
• Being familiar with and identifying
“warning flags” described in the Company’s
U.S. Economic Sanctions Compliance
Commitment and Policy Statement.
• Refusing to participate in
international boycotts.
• Following regulations regarding the
import or export of specified goods,
services, or technologies.
22 PRINCIPLE 3: PROTEC TING OUR COMPANY AND INVESTORS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 23

PRINCIPLE 3 MAINTAINING ACCURATE BOOKS AND RECORDS

PROTECTING OUR Doing the Right Thing HOW We Do It • Any spending of Company funds must be

COMPANY AND INVESTORS

within your authority under the Approval
We implement an effective system As a company, we follow three key principles: and Authorization Guidelines and
of internal controls to ensure our • Maintain, and require all Team Members Approval and Authorization Policy.
internal books and records are to comply with, our internal controls. • Transactions with customers and third
We have a responsibility to grow and protect the Company accurate and complete. • Ensure that our internal books and parties are structured or recorded in a

while enhancing shareholder value records are prepared with the highest
standard of care and accurately reflect
manner consistent with the Company’s
policies and procedures for engaging,
WHY We Do It our financial transactions. contracting, and paying third parties.
The trust of the public, regulators, and • Provide reports and documents • All third parties undergo our screening and
our investors is paramount. If we lose that to the public and our regulators due diligence process, and contracts with
trust, we undermine the Company’s ability that are complete, accurate, timely, them are tracked, typically via Ariba, the
to operate. Part of maintaining that trust and understandable. automated system that helps us manage
is making sure we have a thorough and our relationships.
In addition, each individual Team Member is
PROTECTING COMPANY RESOURCES complete system of internal controls. There
can be no question about the accuracy of
responsible for making sure:

Company books and records or the integrity

• All transactions are transparent and Learn More
accurate. Do not establish, for any
of the processes the Company employs. Our • Approval and Authorization Policy
Doing the Right Thing HOW We Do It records must fully and accurately reflect what
purpose, an unauthorized, undisclosed,
• Contracting Overview Policy
We protect Company resources by • Requiring Team Members to sign and
Examples of actually happens each and every time we
or unrecorded fund or asset. Do not make
• Financial Reporting Controls & Procedures
any attempt to hide or disguise the true
using them only for legitimate abide by the Team Member Handbook. Improper Use engage in a business transaction. In addition,
nature or cost of any transaction. Do not
• Accounting Policies
business purposes. • Not using Company resources for the laws under which the Company operates • Consultant Engagement Policy
Borrowing tools to use on a home falsify, omit, alter, or conceal any facts in
personal purposes. have very specific requirements with regard • Complimentary Policy
project; reselling used equipment Company business records.
• Immediately reporting the loss or theft to our books and records.
WHY We Do It of Company property.
for personal profit; using a Company
vehicle to drive for a ride-sharing
The Company knows you need the right • Receiving Compliance Department
service; making personal charges
tools to do your job the right way. In some approval for use of a Company asset
on a Company credit card, even
cases, those tools may literally be a hammer
or a screwdriver; in other cases, it could
for political purposes.
if you intend to pay it back; Key Information
spending Company time working
be a computer, a copier, or the linens we When the Code refers to “books and
use in guest suites. Our job is to use those
Learn More on a side business.
records” or “business records,” it is
resources honestly and efficiently for • Team Member Handbook not limited to the formal accounting
legitimate business purposes. If our resources ledgers kept by the Company. It
are wasted or unavailable, our business includes any document, whether hard
will be disrupted. copy or electronic, that is created
or used in the course of accounting
for the Company’s operations. This
includes emails, spreadsheets,
presentations, memos, invoices,
purchase orders, and expense reports,
as just a few examples. All of these
records must be accurate and truthful.
You are accountable for the accuracy of
the records you create or maintain.
24 PRINCIPLE 3: PROTEC TING OUR COMPANY AND INVESTORS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 25

AVOIDING CONFLICTS OF INTEREST

Doing the Right Thing HOW We Do It KEY Concepts
• Do not accept gifts or entertainment
We work diligently to identify and • Following the detailed Conflict of Interest
that could unduly influence our
prevent situations in which Covered Policy that requires us to disclose and
business decisions in order to ensure
Persons’ interests conflict or appear resolve all conflicts.
that we award business solely on
to conflict with the best interests of • Avoiding any personal or private interest
the merits and at the best terms and
the Company. that does, could, or appears to influence
conditions for the Company.
our independent judgment or conflicts
• Do not engage in secondary
with the Company’s interests.
WHY We Do It • Providing written notice to the Company
employment or have an outside
business interest that conflicts with
Our investors and fellow Team Members of any actual, perceived, or potential
your responsibilities to, or competes
expect that in everything we do at work we conflicts of interests, as soon as the
with, the Company.
act in the best interests of Las Vegas Sands. Covered Person becomes aware
• Ensure that your personal
We bring fair and unbiased independent of the situation by:
relationships, whether family, friends,
judgment to our work so we can maximize –– Completing the Disclosure Form
or otherwise, do not improperly
shareholder value and help grow the attached to the Conflict of Interest
influence your decisions at work.
Company. A conflict of interest exists where Policy, or
• Make sure your activities outside of
a Covered Person has a personal or private –– Using the reporting tool in ServiceNow
work do not interfere with your job
interest that does, could, or appears to (our electronic portal).
responsibilities, reflect poorly on
interfere with the Covered Person’s ability • Prioritizing advancement of the Company’s
the Company, or create a conflict
to do a job fairly and ethically, or that legitimate business interests.
with the Company’s business goals.
compromises his or her position of trust
Requisite approvals must be sought,
with the Company.
for example, for certain management
levels to serve on a board of directors
or executive level of a public or
private company or a non-profit or
industry board or association.
• Do not use Company information,
property, or authority in pursuing Examples
outside financial interests.
Actual Conflict: Jane in the Horticulture Potential Conflict: Sarah works in IT. For Perceived Conflict: Fred manages a team
• Do not use your position or Company
Department is overseeing a bid for a new almost 10 years she worked for Acme Corp., of about 50 Team Members. At a social
resources (1) to take opportunities
flower supplier. Her husband owns a flower which is now bidding on an IT contract event, Fred hears that John, who is on
away from LVS, (2) for personal gain, or
company and submits a bid for the job. with Las Vegas Sands. Sarah is not directly Fred’s team, is selling a vintage car. Fred is
(3) to compete against the Company.
Even though the husband’s bid is higher involved in the contracting process, but a collector. Fred asks John about the car
cost, Jane selects him for the contract she will work closely with whomever is and John says he has it listed for $15,000,
without disclosing their relationship. selected and may be asked for performance but will give it to Fred for $12,000 because
Learn More Jane violated the policy both by failing to feedback. Sarah raises this issue with her he wants to “sell it quickly.” Should Fred
• Conflict of Interest Policy disclose the relationship and by letting the supervisor and they agree she will not be accept? Probably not. Other Team Members
• Anti-Corruption Policy relationship influence the award of consulted about vendor selection and any may view John’s discount as an attempt to
• Third Party Travel, Gifts the contract. performance reviews of the selected vendor gain favor with the boss. Even if $12,000 is
& Entertainment Policy will be screened by the supervisor. Sarah a reasonable price, the apparent discount
• Complimentary Policy and her supervisor have appropriately gives the appearance of an inappropriate
• Team Member Travel and Expense Policy resolved this potential conflict. gift to a supervisor.
• Competition Policy
• Team Member Handbook
26 PRINCIPLE 3: PROTEC TING OUR COMPANY AND INVESTORS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 27

SAFEGUARDING COMPANY CONFIDENTIAL RESPECTING TRADE SECRETS OF OTHERS

INFORMATION AND INTELLECTUAL PROPERTY
Doing the Right Thing HOW We Do It Q&A
• Prohibiting disclosure of confidential
Doing the Right Thing information to third parties without Key Definitions We follow the golden rule, respecting • Respecting the confidential information Q : I P R E V I O U S LY W O R K E D
the trade secrets and intellectual and intellectual property, such as FOR A COMPETITOR OF
We protect the Company’s written authorization.
• Intellectual Property: Any work property of our competitors as if they trademarks, logos, designs, copyrights, LAS VEGAS SANDS. IN MY
confidential and proprietary • Only disseminating information to and
of invention that is developed as a were our own. and patents, of our competitors JOB, I HAD ACCESS TO
information by not disclosing it sharing access to documents or systems
result of creativity and which can be and other third parties. C O N F I D E N T I A L I N F O R M AT I O N
to any unauthorized persons. with Team Members specifically authorized
protected under law. For example, • Using only lawful means to obtain ABOUT MY EMPLOYER’S
for access.
marketing materials, ads, and game
WHY We Do It information about our competitors. FUTURE DEVELOPMENT
• Protecting information entrusted to us by
WHY We Do It third parties and business partners as if it
designs or processes. We are committed to competing fairly • Never publicly commenting on a S T R A T E G Y. C A N I S H A R E T H I S
• Confidential Information: All and ethically. We expect our competitors competitor’s products or services in I N F O R M AT I O N W I T H M Y N E W
Las Vegas Sands has invested significant was Company information.
material private or proprietary to respect our intellectual property, trade an inaccurate or untruthful manner. T E A M AT L A S V E G A S S A N D S ?
time and resources into developing its • Prohibiting Team Members and business
information owned by or secrets, and proprietary information.
business practices and intellectual property. partners from using Company intellectual
pertaining to the Company or its Accordingly, we need to respect their A: No! We have an obligation to
Unauthorized disclosure of this information property for personal or outside
executives, vendors, and guests property as well. This is not only the
Learn More our competitors and you have an
could destroy its value to the Company and business ventures.
that was learned as a result of your right thing to do but is required by law. • Contact the Legal and/or obligation to your former employer
give an unfair advantage to others. Each of • Requiring the Las Vegas Sands’ CEO’s
relationship with the Company. Competitors’ intellectual property may Compliance Departments to protect their confidential
us must diligently protect the Company’s approval for any grant of naming rights
This includes, for example, customer be protected by trademark, copyright, information from unauthorized access
confidential business and technical to a Company venue.
lists, financial records, and Team and patent laws. Their trade secrets or disclosure. As such, any attempt
information as we do its tangible property.
Member records. and proprietary information may to share, profit, or gain from the
Learn More also be protected under various fair confidential information of others
HOW We Do It • Team Member Handbook
competition statutes. would not only be unethical but also a
breach of our Code of Conduct.
• Requiring Team Members to abide by • Confidential Information Policy
the Confidentiality Agreement or
Confidential Information Policy in the
Team Member Handbook.
28 PRINCIPLE 3: PROTEC TING OUR COMPANY AND INVESTORS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 29

COMPLYING WITH SECURITIES TRADING LAWS PROPERLY COMMUNICATING OUTSIDE THE COMPANY
regulators. Therefore, Team Members should
Doing the Right Thing HOW We Do It Key Definitions Doing the Right Thing not discuss confidential Company business
Direct Media Inquiries to
We comply with all securities trading As a Company we: We speak with one voice. with members of the press, investors, or • U.S. and Corporate: 702.414.3218
• Material Non-Public Information:
laws and do not allow our Team • Promulgate the Securities Trading Policy market analysts without authorization. • Macao: +853 811 72143
Information that a reasonable
Members to use inside information to and the Confidential Information Policy. • Singapore: mediarelations@
trade in the markets. • Require that new hires receive and
investor would consider important WHY We Do It marinabaysands.com
acknowledge the Securities Trading Policy.
in a decision to buy, hold, or sell a
Our Company is frequently in the news. It
HOW We Do It
stock. For example, you learn that
• Provide annual training for all Team may be a routine earnings report, a celebrity Directing all requests to talk about Company
WHY We Do It Members on the Securities Trading Policy.
the Company is going to report
attending an event, or an unusual occurrence business from members of the press,
higher than expected earnings next
Securities laws aim to ensure the buying and at our property. How we respond to media investors, or market analysts to our Corporate
Covered Persons and their Immediate Family week. You cannot trade in Company
selling of publicly traded securities – such requests can impact how the Company Communications and/or our Investor
Members are prohibited from: stock until after the earnings are
as our Company’s stock – is done fairly. is perceived by the public, investors, and Relations office.
• Trading in Company stock while in reported. Likewise, if you find out
Everyone buying or selling stock should have
possession of Material Non-Public that LVS is about to sign a big
access to the same information. Maintaining
(“Inside”) Information. contract with a vendor, you cannot
the confidence of the investing public is
• Tipping. go out and buy stock in the vendor
crucial to maintaining shareholder value.
• Trading Company stock outside the until the contract is announced.
Trading on inside information and tipping
Company’s trading window if they are on • Immediate Family Member: Spouse,
are both unethical and illegal; violations
carry serious penalties. In addition to strict
the Company’s restricted trading list and minor children, or anyone else living SAFELY USING SOCIAL MEDIA
are required to pre-clear any transaction. in your household.
legal compliance, we strive to avoid even the
• Tipping: Providing Material
appearance of impropriety and to protect
the Company’s reputation for honesty Learn More Non-Public Information to a third Doing the Right Thing HOW We Do It Q&A
party not authorized to have the
and integrity. We balance our Team Members’ • Recognizing that social media posts are Q: A C E L E B R I T Y WA S O N
• Securities Trading Policy (Code for SCL) information (even if you don’t know
rights to express themselves with still governed by our confidentiality rules. P R O P E R T Y A N D I WA S A B L E
• Confidential Information Policy whether the third party intends to
the obligation to properly represent • Distinguishing between authorized TO SNAP A FEW QUICK
trade based on the information).
the Company. business communications and PICTURES. CAN I POST
personal communications. THESE TO MY SOCIAL MEDIA
• Requiring Team Members who endorse ACCOUNT?
WHY We Do It our property on social media to identify
Social media is all around us today. It gives themselves as Team Members of A: No! As discussed elsewhere, we
individuals the power to connect with one the Company. protect our guests’ privacy and do not
another and express their views to a wide • Not allowing social media to interfere with make unauthorized communications
audience. While the Company respects doing your job. about Company business. Posting the
individuals’ right to express themselves photos would violate both principles.
in social media, we all need to be aware
that when we do so we may be seen as a
Learn More
representative of the Company. We have • If you have any questions, ask your
a responsibility to protect the Company’s supervisor or Human Resources
confidential information and reputation • Team Member Handbook
when we use social media.

Important note: In some countries where we operate, the law allows Team Members to freely communicate with one another and third parties
about terms of employment and working conditions. Nothing in this Code is meant to limit that right, but you must still adhere to rules around
confidentiality and privacy.
30 PRINCIPLE 4: ENHANCING OUR COMMUNITIES CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 31

PRINCIPLE 4 CONDUCTING BUSINESS SUSTAINABLY

ENHANCING OUR Doing the Right Thing HOW We Do It • Promoting responsible business conduct

COMMUNITIES
that upholds environmental regulatory
We are committed to protecting the • Promulgating policies to promote requirements and demonstrates industry-
environment by practicing sustainable environmental responsibility and leading practices where formal legal
development and conserving sustainable procurement. standards are not in place.
We are part of a larger community and look for ways natural resources. • Developing Sands ECO360, a holistic • Establishing strategic relationships

to positively impact the world around us global sustainability program which

addresses key issues including energy,
with various organizations to create
transformational change in the regions in
WHY We Do It water, and waste. which we operate.
Our responsibility to the planet is as • Using a formal environmental • Using third-party rating standards and
important to us as our commitment to the management system to identify the certifications to measure our sustainability
comfort and well-being of our guests and impacts of our operations, establish performance and improve our methods.
Team Members. Our global sustainability priorities, set performance goals, and • Providing Team Members and other
strategy is designed to help minimize our continuously monitor our Sands stakeholders with opportunities to
environmental impact, and it reflects our ECO360 program. learn about and contribute to our
PARTICIPATING IN CIVIC AND GOVERNMENT ACTIVITIES vision to lead the way in sustainable building • Producing an annual progress report sustainability efforts.
development and resort operations. sharing our sustainability efforts
and achievements.
Doing the Right Thing • Prohibit Team Members from directly or
• Conducting environmental risk and
Learn More
indirectly making political contributions
We ethically engage in civic activities to on behalf of the Company or with
Q&A opportunity assessments and developing • Environmental Responsibility Policy
mitigation plans. • Sustainable Procurement Policy
advocate on behalf of the Company and Company funds unless it is legal and prior Q : L A S T S AT U R D AY,
• Sustainable Development Standards
encourage Team Members to individually approval is received. I AT T E N D E D A P O L I T I C A L
• Sands ECO360 Report
participate in civic activities. • Never exert improper influence on any R A L LY W H E R E I W A S
government agency or representative to INTERVIE WED BY A LOC AL
gain a favorable outcome for the Company. N E W S S T AT I O N . W H E N A S K E D
WHY We Do It • Conduct due diligence on charitable T O I N T R O D U C E M Y S E L F, I ECO360 How to Make
Constructively engaging in civic activities in contributions or sponsorships made to T O L D T H E R E P O R T E R T H AT I
every region in which we operate helps the civic events or organizations to ensure such A M A T E A M M E M B E R AT L A S strategy pillars EN
VI
RO
a Difference
N
Company achieve its goals and contributes contributions are proper and legitimate. V E G A S S A N D S C O R P. W A S I T G
S M
E • Conserving: Use less water, paper,
IN O N
to public discourse on important issues. O K T O M E N T I O N T H AT ? P and electricity by turning off lights,

D
As individual Team Members we:

TA AT
IL

E
Likewise, when Team Members responsibly setting computers to “sleep” mode,

LL ION
R
BU
• Speak and act solely in a personal capacity A: Because you are engaging in the

Y
participate in the political process or civic printing double-sided or not at all,

RE
and not on behalf of the Company. political process as a private citizen, and

EE
activities in a personal capacity, they using reusable mugs and water

SP
S
GR
• Disclose to the Company any political not a representative of Las Vegas Sands

O
also promote open and vibrant societies. bottles, and using hand dryers

NSIBLE
engagement that may pose an actual Corp., refrain from associating yourself
Adhering to all applicable laws and high instead of paper towels.
or potential conflict of interest. with the Company. If a third party
ethical standards in conducting such • Engaging and Learning: Participate
identifies you as a Team Member, make
activities – as a Company and as individuals – in Sands ECO360 activities such
clear that your statements and actions
ensures fair and inclusive political processes. Learn More as assembling hygiene kits with

GR
are your own and do not represent those

EN R
repurposed amenities from hotel

EE

EM DE
T
AN
• Anti-Corruption Policy of the Company.

G OL
rooms, planting trees, the Clean Plate
HOW We Do It

D
M
• Charitable Contributions

H
EV
E
Challenge, building community

E
E
IN
and Sponsorship Policy

K
A

T
E

A
T G T

N
As a Company we: S S gardens, property tours, and

G
S N
• Conflict of Interest Policy E
• Comply with all applicable political sustainability education sessions.
• Third Party Travel, Gifts &
campaign finance and election laws.
Entertainment Policy
• Pennsylvania Political Influence Policy
32 MAKING SURE THE CODE WORKS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 33

MAKING SURE
THE CODE WORKS
The Global Compliance The Company’s Operational Compliance How We Investigate Disciplinary Action
Committees at the property level help ensure
Department the Code is properly implemented and Misconduct The Code is very important to the Company.
Failure to comply with the standards outlined
The Global Compliance Department, administered. These committees report to Reports of alleged misconduct come into
herein and all policies referred to herein
under the management of the Company’s the Board of Directors through the Global the Company in a variety of ways, including
will result in disciplinary action, up to and
Global Chief Compliance Officer, has Chief Compliance Officer and the Board’s the Ethics Hotline, direct emails, and through
including termination, where permitted by
primary responsibility for this Code of Compliance Committee. management reporting. The Company takes
law. Some violations of the Code or other
Conduct. This includes issuing it, keeping it all good faith reports seriously and protects
Company policy are serious enough to
updated, answering questions about it, and The Board of Directors’ Compliance those making them from retaliation. All
warrant dismissal in the first instance.
investigating and remediating any alleged Committee provides oversight of the reports of alleged violations of this Code will
violations of the Code. The Compliance Company’s compliance program with be assigned to an appropriate investigator
Disciplinary action will be taken against:
Department works with many other respect to (a) compliance with the laws and to conduct a prompt, fair, and thorough
• Any Team Member who violates the Code
departments of the Company and will make regulations applicable to the Company’s investigation.
or pertinent law.
sure that in any matter related to this Code business, including gaming laws; and
• Any Team Member who deliberately
the most appropriate resources are involved. (b) compliance with the Code, its Anti- All information obtained during the course
withholds relevant information concerning
Corruption Policy, its Anti-Money of the investigation will remain confidential,
a violation of the Code or pertinent law.
In addition to all other ways in which you Laundering Policy, and its Reporting and except as necessary to conduct the
• The Team Member’s manager or supervisor
can report allegations of misconduct, illegal Non-Retaliation Policy. investigation and take any remedial action,
to the extent that the circumstances of
activity, or violations of the Code, or ask and in accordance with applicable law.
the violation reflect participation in the
questions about the Code and the laws The Board of Directors’ Audit Committee Similarly, we ask Team Members involved
violation, or lack of diligence.
under which the Company operates, you can provides oversight of the Company’s internal in the investigation to keep all information
• Any Team Member who retaliates, directly
always contact the Compliance Department. controls and financial matters. confidential to allow a fair and impartial
or indirectly, or encourages others to do
investigation to proceed. Nothing in this
so, against a Team Member who reports a
Code prohibits you from reporting possible
Other Resources Seeking Guidance violations of federal law or regulation to any
Code, policy, or law violation.
• Any Team Member who knowingly falsely
in the Company As we have seen, there are many ways for you
to seek guidance or report a concern – choose
applicable governmental agency or entity.
accuses another Team Member of a Code,
Human Resources partners closely with the policy, or law violation.
the way that is most comfortable for you. Key If, at the conclusion of the investigation,
Compliance Department in administering,
contacts are listed at the end of this Code, it is determined a violation of this Code
and resolving issues that arise under, the In addition, the Board of Directors of the
but you can always use the Ethics Hotline to has occurred, the Company will take
Code. It is responsible for matters that Company has adopted a Clawback Policy
seek help: prompt remedial action commensurate
relate to the terms and conditions of Team which requires a Team Member to return
• Website: www.lvscethics.com with the severity of the offense. This action
Members’ employment. It can be contacted a bonus to the Company where the bonus
• Phone: may include disciplinary action against
with respect to any issue and is likely to was achieved as a result of the Team
–– United States: 888.469.1536 the accused party, up to and including
be the most appropriate place to initially Member’s misconduct.
–– Singapore: SingTel 800-011-1111 or termination. Reasonable and necessary
raise issues related to discrimination and
StarHub 800-001-0001, followed by steps will also be taken to prevent any
harassment, as well as workplace treatment
888-418-1029 at prompt further violation of the policy at issue. When
and conditions.
–– Macao: 0800-111 followed by consistent with law and our confidentiality
888-418-1029 obligations, we will make every effort to
advise the reporting party about the closure
of the matter.
34 MAKING SURE THE CODE WORKS CODE OF BUSINESS CONDUCT AND ETHICS LAS VEGAS SANDS CORP. 35

Your Obligation to Help • Lie or make false or misleading statements

to any governmental investigator.
This Code Is Not WHO TO CONTACT
If you discover what you in good faith believe
• Attempt to persuade any Covered Person, a Contract
are actions in violation of this Code, or are of
a questionable, fraudulent, or illegal nature,
or any other person, to provide false or This Code is not an employment contract. Compliance
misleading information to a governmental Adherence to the standards of the Code,
you must report the matter immediately. You • Corporate Global: [email protected]
investigator, to destroy or alter any however, is a condition of continued
will be protected from retaliation in any form or 702.607.4628 (Global Chief
document or record, or to fail to fully employment at the Company. This Code
or manner. You have a duty to cooperate Compliance Officer)
and truthfully cooperate with a does not give you rights of any kind, and
truthfully and fully in the investigation of any • United States: [email protected] or
governmental inquiry. may be changed by the Company at any
alleged violation of the Code. In addition, a 702.607.4628 (U.S. Compliance Officer)
time without notice. Unless governed by a • Singapore: MBSCompliance@
Team Member may be subject to disciplinary
Nothing in this Code should be interpreted collective bargaining agreement, written
action, including termination of employment, MarinaBaySands.com (Chief Compliance
as prohibiting or discouraging you from employment contract, or you are employed
if the Team Member fails to cooperate in an Officer of MBS)
testifying, participating, or otherwise outside the United States in a country
investigation, deliberately provides false or • Macao: [email protected] or
assisting in any state, federal, judicial, or where the applicable law may be different,
misleading (including diverting, misdirecting, +853 811 82273 (Chief Compliance Officer
legislative proceeding or inquiry. employment with the Company is “at will,”
or offering incomplete) information during of SCL & VML)
which means that you or the Company
an investigation, or deliberately conceals
may terminate your employment for
or destroys records or anything in order to Waivers and Amendments any reason or no reason, with or without Legal
hinder the investigation. Any specific waiver of the Code for the notice, at any time. This at-will employment • Corporate Global: 702.414.4713
principal executive officer, principal financial relationship may not be modified except (Global General Counsel)
Government Investigations officer, principal accounting officer (or
persons performing similar functions), other
in a written agreement signed by the Team • United States: 702.607.3163 (General
As a regulated entity, we may occasionally be Member and an authorized representative Counsel, Venetian Casino Resort, LLC)
executive officers (Senior Vice President and of the Company.
asked to respond to a government inquiry • Marina Bay Sands: +65 6688 1218
above), or member of the Board of Directors
or investigation. In any interactions with the (General Counsel)
will be made only by the Company’s Audit
government we will act lawfully and provide • Sands China Ltd.: +853 811 82366
information truthfully and to the best of
Committee and will be promptly disclosed Acknowledgment (General Counsel)
as required by law. Any specific waiver of Each Team Member is required to certify his
our knowledge and ability. To ensure that
the Code for any other Covered Person will or her understanding of and compliance with
we adhere to these rules and to protect the
be made by the Global Chief Compliance the terms of this Code and related policies by
Human Resources
Company’s interests, you must seek advice
Officer. All such waivers shall be reported electronically acknowledging that he or she • Corporate Global: 702.414.3243
from the Legal or Compliance Departments
by the Global Chief Compliance Officer to has received a copy of the Code. Be sure you (SVP of Global Human Resources)
before responding to a non-routine request
the Compliance Committee and the Audit have taken the time to read and understand • Venetian Casino Resort: 702.414.4266
for information directed at the Company
Committee at their next regularly scheduled the Code before signing the electronic (SVP of Human Resources)
from a government or regulatory agency.
meeting. Any amendment of the Code will acknowledgment, which is accessible in • Marina Bay Sands: +65 6688 1611
If you are contacted by a government
be made only by the Company’s Board of your online training package. Other Covered (SVP of Human Resources)
investigator, we ask that you contact the
Directors and will be promptly disclosed Persons should read and sign the attached • Sands China Ltd.: +853 811 86146 / + 853
Global Chief Compliance Officer or General
as required by law or regulation. form and submit it to your contact at the 811 86147 (SVP of Human Resources)
Counsel for your group.
Company. If, in good faith, you believe you
You must never under any circumstance: cannot sign the electronic acknowledgment, Ethics Hotline
• Destroy or alter any Company document you must advise your supervisor or the Chief
Website:
or record, including emails and other Compliance Officer for your region of your
www.lvscethics.com
electronic records, in anticipation of a reasons for not signing and provide the
request for the document or record by a information requested on the Good Faith Phone:
governmental agency or court. Objection Form, which can also be accessed • United States: 888.469.1536
in your online training package. • Singapore: SingTel 800-011-1111 or
StarHub 800-001-0001, followed by
888-418-1029 at prompt
• Macao: 0800-111 followed by
888-418-1029 at prompt
www.sands.com