SERVICES SECTOR CASINOS & GAMING Sustainability Accounting Standard Sustainable Industry Classification System® (SICS®) SV-CA Prepared by the Sustainability Accounting Standards Board October 2018 INDUSTRY STANDARD | VERSION 2018-10 © 2018 The SASB Foundation. All Rights Reserved. sasb.org CASINOS & GAMING Sustainability Accounting Standard About SASB The SASB Foundation was founded in 2011 as a not-for-profit, independent standards-setting organization. The SASB Foundation’s mission is to establish and maintain industry-specific standards that assist companies in disclosing financially material, decision-useful sustainability information to investors. The SASB Foundation operates in a governance structure similar to the structure adopted by other internationally recognized bodies that set standards for disclosure to investors, including the Financial Accounting Standards Board (FASB) and the International Accounting Standards Board (IASB). This structure includes a board of directors (“the Foundation Board”) and a standards-setting board (“the Standards Board” or "the SASB"). The Standards Board develops, issues, and maintains the SASB standards. The Foundation Board oversees the strategy, finances and operations of the entire organization, and appoints the members of the Standards Board. The Foundation Board is not involved in setting standards, but is responsible for overseeing the Standards Board’s compliance with the organization’s due process requirements. As set out in the SASB Rules of Procedure, the SASB’s standards-setting activities are transparent and follow careful due process, including extensive consultation with companies, investors, and relevant experts. The SASB Foundation is funded by a range of sources, including contributions from philanthropies, companies, and individuals, as well as through the sale and licensing of publications, educational materials, and other products. The SASB Foundation receives no government financing and is not affiliated with any governmental body, the FASB, the IASB, or any other financial accounting standards-setting body. SUSTAINABILITY ACCOUNTING STANDARDS BOARD 1045 Sansome Street, Suite 450 San Francisco, CA 94111 415.830.9220 info@sasb.org sasb.org The information, text, and graphics in this publication (the “Content”) are owned by The SASB Foundation. All rights reserved. The Content may be used only for non-commercial, informational, or scholarly use, provided that all copyright and other proprietary notices related to the Content are kept intact, and that no modifications are made to the Content. The Content may not be otherwise disseminated, distributed, republished, reproduced, or modified without the prior written permission of The SASB Foundation. To request permission, please contact us at info@sasb.org. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 2 Table of Contents Introduction....................................................................................................................................................................4 Purpose of SASB Standards.........................................................................................................................................4 Overview of SASB Standards.......................................................................................................................................4 Use of the Standards...................................................................................................................................................5 Industry Description.....................................................................................................................................................5 Sustainability Disclosure Topics & Accounting Metrics...............................................................................................7 Energy Management...................................................................................................................................................8 Responsible Gaming..................................................................................................................................................10 Smoke-free Casinos...................................................................................................................................................12 Internal Controls on Money Laundering.....................................................................................................................14 SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 3 INTRODUCTION Purpose of SASB Standards The SASB’s use of the term “sustainability” refers to corporate activities that maintain or enhance the ability of the company to create value over the long term. Sustainability accounting reflects the governance and management of a company’s environmental and social impacts arising from production of goods and services, as well as its governance and management of the environmental and social capitals necessary to create long-term value. The SASB also refers to sustainability as “ESG” (environmental, social, and governance), though traditional corporate governance issues such as board composition are not included within the scope of the SASB’s standards-setting activities. SASB standards are designed to identify a minimum set of sustainability issues most likely to impact the operating performance or financial condition of the typical company in an industry, regardless of location. SASB standards are designed to enable communications on corporate performance on industry-level sustainability issues in a cost-effective and decision-useful manner using existing disclosure and reporting mechanisms. Businesses can use the SASB standards to better identify, manage, and communicate to investors sustainability information that is financially material. Use of the standards can benefit businesses by improving transparency, risk management, and performance. SASB standards can help investors by encouraging reporting that is comparable, consistent, and financially material, thereby enabling investors to make better investment and voting decisions. Overview of SASB Standards The SASB has developed a set of 77 industry-specific sustainability accounting standards (“SASB standards” or “industry standards”), categorized pursuant to SASB’s Sustainable Industry Classification System® (SICS®). Each SASB standard describes the industry that is the subject of the standard, including any assumptions about the predominant business model and industry segments that are included. SASB standards include: 1. Disclosure topics – A minimum set of industry-specific disclosure topics reasonably likely to constitute material information, and a brief description of how management or mismanagement of each topic may affect value creation. 2. Accounting metrics – A set of quantitative and/or qualitative accounting metrics intended to measure performance on each topic. 3. Technical protocols – Each accounting metric is accompanied by a technical protocol that provides guidance on definitions, scope, implementation, compilation, and presentation, all of which are intended to constitute suitable criteria for third-party assurance. 4. Activity metrics – A set of metrics that quantify the scale of a company’s business and are intended for use in conjunction with accounting metrics to normalize data and facilitate comparison. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 4 Furthermore, the SASB Standards Application Guidance establishes guidance applicable to the use of all industry standards and is considered part of the standards. Unless otherwise specified in the technical protocols contained in the industry standards, the guidance in the SASB Standards Application Guidance applies to the definitions, scope, implementation, compilation, and presentation of the metrics in the industry standards. The SASB Conceptual Framework sets out the basic concepts, principles, definitions, and objectives that guide the Standards Board in its approach to setting standards for sustainability accounting. The SASB Rules of Procedure is focused on the governance processes and practices for standards setting. Use of the Standards SASB standards are intended for use in communications to investors regarding sustainability issues that are likely to impact corporate ability to create value over the long term. Use of SASB standards is voluntary. A company determines which standard(s) is relevant to the company, which disclosure topics are financially material to its business, and which associated metrics to report, taking relevant legal requirements into account1. In general, a company would use the SASB standard specific to its primary industry as identified in SICS® . However, companies with substantial business in multiple SICS® industries can consider reporting on these additional SASB industry standards. It is up to a company to determine the means by which it reports SASB information to investors. One benefit of using SASB standards may be achieving regulatory compliance in some markets. Other investor communications using SASB information could be sustainability reports, integrated reports, websites, or annual reports to shareholders. There is no guarantee that SASB standards address all financially material sustainability risks or opportunities unique to a company’s business model. Industry Description Publicly held casinos and gaming companies operate gambling facilities and/or platforms, including brick-and-mortar casinos, riverboat casinos, online gambling websites, and racetracks. The broader industry in the U.S. is dominated by privately held Native American casinos, which significantly outnumber publicly held casinos. Native American casinos are generally owned and operated by tribes, but sometimes can be managed by commercial casino operators or other management companies. The industry is characterized by high levels of regulatory oversight, which represents the main barrier to entry for new operators. Fewer than half of U.S. states have legalized commercial casinos in some form, although industry regulation varies significantly worldwide. Note: Select companies in the Casinos & Gaming industry are also engaged in activities of the Hotels & Lodging and/or Restaurants industries. The SASB Standards for such activities are outlined in the Hotels & Lodging and Restaurants standards. For the purposes of this standard, it is assumed that casinos and gaming companies are engaged solely in operating gambling facilities and providing online gaming services, and therefore issues such as water management and 1 Legal Note: SASB standards are not intended to, and indeed cannot, replace any legal or regulatory requirements that may be applicable to a reporting entity’s operations. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 5 food safety, which may be material for companies that have significant hotel and restaurant operations, are not covered by this industry standard. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 6 SUSTAINABILITY DISCLOSURE TOPICS & ACCOUNTING METRICS Table 1. Sustainability Disclosure Topics & Accounting Metrics UNIT OF TOPIC ACCOUNTING METRIC CATEGORY CODE MEASURE Energy (1) Total energy consumed, (2) percentage grid Gigajoules (GJ), Quantitative SV-CA-130a.1 Management electricity, (3) percentage renewable Percentage (%) Percentage of gaming facilities that implement Percentage (%) Quantitative SV-CA-260a.1 the Responsible Gambling Index by revenue Responsible Percentage of online gaming operations that Gaming implement the National Council on Problem Percentage (%) Quantitative SV-CA-260a.2 Gambling (NCPG) Internet Responsible by revenue Gambling Standards Percentage (%) Percentage of gaming floor where smoking is Quantitative of gaming floor SV-CA-320a.1 allowed Smoke-free area Casinos Percentage of gaming staff who work in areas Percentage (%) Quantitative SV-CA-320a.2 where smoking is allowed of man-hours Description of anti-money laundering policies Discussion and n/a SV-CA-510a.1 Internal and practices Analysis Controls on Money Total amount of monetary losses as a result of Reporting Laundering legal proceedings associated with money Quantitative SV-CA-510a.2 currency laundering2 Table 2. Activity Metrics UNIT OF ACTIVITY METRIC CATEGORY CODE MEASURE Number of tables Quantitative Number SV-CA-000.A Number of slots Quantitative Number SV-CA-000.B Number of active online gaming customers3 Quantitative Number SV-CA-000.C Square meters Total area of gaming floor Quantitative SV-CA-000.D (m²) 2 Note to SV-CA-510a.2 – The entity shall briefly describe the nature, context, and any corrective actions taken as a result of the monetary losses. 3 Note to SV-CA-000.C – The number of active customers shall be considered as the number for which there was at least one financial transaction (bet, deposit, withdraw) with real currency within the reporting period, where real currency is defined by the U.S. Financial Crimes Enforcement Network. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 7 Energy Management Topic Summary With many facilities open 24 hours a day, the Casinos & Gaming industry requires a large amount of energy to operate. Casino facilities often have few windows and therefore rely on their buildings’ mechanical systems for heating, ventilation, air-conditioning (HVAC), and lighting. Fossil fuel-based energy production and consumption contribute to significant environmental impacts, including climate change and pollution, and have the potential to impact casino companies’ results of operations. It is becoming increasingly important for companies that rely on electricity consumption for their operations to manage energy efficiency as well as energy availability, including the risks and opportunities associated with energy sourcing from fossil fuels and/or from renewable and alternative energy sources. Accounting Metrics SV-CA-130a.1. (1) Total energy consumed, (2) percentage grid electricity, (3) percentage renewable 1 The entity shall disclose (1) the total amount of energy it consumed as an aggregate figure, in gigajoules (GJ). 1.1 The scope of energy consumption includes energy from all sources, including energy purchased from sources external to the entity and energy produced by the entity itself (self-generated). For example, direct fuel usage, purchased electricity, and heating, cooling, and steam energy are all included within the scope of energy consumption. 1.2 The scope of energy consumption includes only energy directly consumed by the entity during the reporting period. 1.3 In calculating energy consumption from fuels and biofuels, the entity shall use higher heating values (HHV), also known as gross calorific values (GCV), which are directly measured or taken from the Intergovernmental Panel on Climate Change (IPCC), the U.S. Department of Energy (DOE), or the U.S. Energy Information Administration (EIA). 2 The entity shall disclose (2) the percentage of energy it consumed that was supplied from grid electricity. 2.1 The percentage shall be calculated as purchased grid electricity consumption divided by total energy consumption. 3 The entity shall disclose (3) the percentage of energy it consumed that is renewable energy. 3.1 Renewable energy is defined as energy from sources that are replenished at a rate greater than or equal to their rate of depletion, such as geothermal, wind, solar, hydro, and biomass. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 8 3.2 The percentage shall be calculated as renewable energy consumption divided by total energy consumption. 3.3 The scope of renewable energy includes renewable fuel the entity consumed, renewable energy the entity directly produced, and renewable energy the entity purchased, if purchased through a renewable power purchase agreement (PPA) that explicitly includes renewable energy certificates (RECs) or Guarantees of Origin (GOs), a Green‐e Energy Certified utility or supplier program, or other green power products that explicitly include RECs or GOs, or for which Green‐e Energy Certified RECs are paired with grid electricity. 3.3.1 For any renewable electricity generated on-site, any RECs and GOs must be retained (i.e., not sold) and retired or cancelled on behalf of the entity in order for the entity to claim them as renewable energy. 3.3.2 For renewable PPAs and green power products, the agreement must explicitly include and convey that RECs and GOs be retained or replaced and retired or cancelled on behalf of the entity in order for the entity to claim them as renewable energy. 3.3.3 The renewable portion of the electricity grid mix that is outside of the control or influence of the entity is excluded from the scope of renewable energy. 3.4 For the purposes of this disclosure, the scope of renewable energy from hydro and biomass sources is limited to the following: 3.4.1 Energy from hydro sources is limited to those that are certified by the Low Impact Hydropower Institute or that are eligible for a state Renewable Portfolio Standard; 3.4.2 Energy from biomass sources is limited to materials certified to a third-party standard (e.g., Forest Stewardship Council, Sustainable Forest Initiative, Programme for the Endorsement of Forest Certification, or American Tree Farm System), materials considered eligible sources of supply according to the Green-e Framework for Renewable Energy Certification, Version 1.0 (2017) or Green-e regional standards, and/or materials that are eligible for an applicable state renewable portfolio standard. 4 The entity shall apply conversion factors consistently for all data reported under this disclosure, such as the use of HHVs for fuel usage (including biofuels) and conversion of kilowatt hours (kWh) to GJ (for energy data including electricity from solar or wind energy). SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 9 Responsible Gaming Topic Summary While the main purpose of gambling is entertainment, the industry faces a negative perception that is often related to pathological gambling. In addition to pathological gambling which is a progressive addiction characterized by increasing preoccupation with gambling, customers may also experience problem gambling, a less severe form of pathological gambling. While casinos do not cause problem gambling, they provide opportunities to gamble and may earn disproportionately greater revenue from pathological and problem gamblers. Responsible gambling encompasses industry best practices to mitigate the impacts of problem gambling that may result from violations of self-exclusion lists, irresponsible advertising, gambling by minors, or instances where the company has otherwise enabled gambling problems. Highly-publicized incidents related to pathological and problem gambling may damage companies’ reputations and result in regulatory curtailment of their licenses to operate. Accounting Metrics SV-CA-260a.1. Percentage of gaming facilities that implement the Responsible Gambling Index 1 The entity shall disclose the percentage of its gaming facilities by revenue that implement the Responsible Gambling Index (RG Index) criteria. 1.1 Gaming facility is defined as any entity-owned establishment utilized primarily for the purposes of gaming and where gaming equipment or supplies are operated for the purposes of accruing business revenue, excluding online gaming operations.4 1.2 RG Index criteria are those developed by the Responsible Gambling Council (RGC) Centre for the Advancement of Best Practices. 2 The entity shall calculate the percentage of RG Index criteria achieved for each gaming facility as the number of RG Index criteria for which the facility is in compliance divided by the total number of criteria, as follows: 2.1 The entity shall consider the 47 criteria under the eight core standards: Responsible gambling policies (five criteria), Employee training (eight criteria), Self-exclusion (11 criteria), Assisting patrons who may have problems with gambling (four criteria), Informed decision-making (three criteria), Advertising and promotion (five criteria), Access to money (four criteria), and Venue and game features (seven criteria). 2.2 The entity shall calculate a weighting factor for each gaming facility as the revenue from that facility divided by the entity’s total revenue across all gaming facilities. 4 Smoke Free Illinois Act (410 ILCS 82/). SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 10 2.3 The percentage of criteria achieved by each facility shall be multiplied by its weighting factor and summed across all gaming facilities to determine the percentage for disclosure. 3 The entity may disclose the percentage of its facilities, by revenue, for which RG Index certification has been attained. SV-CA-260a.2. Percentage of online gaming operations that implement the National Council on Problem Gambling (NCPG) Internet Responsible Gambling Standards 1 The entity shall disclose the percentage of its online gaming operations by revenue that implement the National Council on Problem Gambling (NCPG) Internet Responsible Gambling Standards. 1.1 Online games are defined as any entity-owned or operated online platform that enables individuals to place, receive, or otherwise knowingly transmit a bet or wager by any means that involve the use, at least in part, of the internet.5 2 The entity shall calculate the percentage of NCPG criteria achieved for each online gaming website as the number of NCPG criteria for which the facility is in compliance divided by the total number of criteria, as follows: 2.1 The entity shall consider the 34 criteria, which are counted as each sub-element6 under the eight core standards: Policy (three criteria), Staff training (two criteria), Informed decision-making (four criteria), Assisting players (two criteria), Self-exclusion (eight criteria), Advertising and promotion (three criteria), Game and site features (11 criteria), and Research (one criterion). 2.2 The entity shall calculate a weighting factor for each online gaming website as the revenue from that online gaming website divided by the entity's total revenue across all online gaming websites. 2.3 The percentage of criteria achieved by each online gaming website is multiplied by its weighting factor and summed across all online gaming websites to determine the percentage for disclosure. 5 Adapted from 31 U.S. Code § 5362. 6 The NCPG Internet Responsible Gambling Standards sub-elements are generally designated as a topic followed by a colon (:) and further explanation of the topic. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 11 Smoke-free Casinos Topic Summary Casino facilities are usually climate-controlled environments with internal air circulation, and have a relatively high concentration of employees and customers. While anti-smoking campaigns have helped some regions enact smoking bans for public places, many casinos remain exempt from such bans. Smoke exposes employees and customers to risks of heart attacks and cancer. In addition, studies have shown that casino dealers exposed to secondhand smoke have higher- than-average rates of respiratory illness. Companies that derive a significant portion of their revenue from smoking customers may be negatively affected by smoking bans, which are becoming more common. Alternatively, by creating smoke-free facilities, casino operators may be better positioned to attract more non-smoking patrons. Accounting Metrics SV-CA-320a.1. Percentage of gaming floor where smoking is allowed 1 The entity shall disclose the percentage of its gaming floor where smoking is permitted (i.e., areas where smoking is not banned by law or designated by the entity as non-smoking). 1.1 Gaming floor is defined as any entity-owned establishment utilized primarily for the purposes of gaming and where gaming equipment or supplies are operated for the purposes of accruing business revenue.7 1.2 Designated non-smoking areas are defined as areas within the casino’s gaming floor that are clearly marked “non-smoking,” are actively monitored for smoking violations, and that are separately ventilated from enclosed indoor areas where smoking is allowed. 1.3 The scope of disclosure excludes areas adjacent to the gaming floor, such as any hallway, reception area, retail space, bar, nightclub, restaurant, hotel, entertainment venue, or office space. 2 The percentage is calculated as the gaming floor area where smoking is permitted divided by the total gaming floor area. 3 The entity may disclose the percentage of its gaming floor area that is mandated by law to be designated non- smoking, calculated as the gaming floor area that is required by law to be designated as non-smoking divided by the total gaming floor area. 7 Smoke Free Illinois Act (410 ILCS 82/). SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 12 SV-CA-320a.2. Percentage of gaming staff who work in areas where smoking is allowed 1 The entity shall disclose the percentage of its gaming staff, on an hours-worked basis, who work in areas where smoking is permitted (i.e., areas where smoking is not banned by law or designated by the entity as non-smoking). 1.1 Gaming staff is defined as any person (1) who is employed by an operator or retailer that hosts gaming to work directly with the gaming portion of its business and (2) who must be twenty-one years of age or older and hold a support license. 1.1.1 Gaming staff include, but are not limited to, dealers; change and counting room personnel; cashiers; floormen; cage personnel; slot machine repairmen or mechanics; persons who accept or transport revenue from a slot, blackjack, or poker-table drop or dropbox; security personnel; shift or pit bosses; floor managers; supervisors; slot machine and slot booth personnel; and any other employees whose main work station is located in a gaming facility.8 1.2 Gaming floor is defined as any entity-owned establishment utilized primarily for the purposes of gaming and where gaming equipment or supplies are operated for the purposes of accruing business revenue.9 1.3 Designated non-smoking areas are defined as areas within the casino’s gaming floor that are clearly marked “non-smoking,” are actively monitored for smoking violations, and that are separately ventilated from enclosed indoor areas where smoking is allowed. 2 The percentage of staff is calculated as the number of gaming staff man-hours worked on the casino’s gaming floor in areas that are not designated as non-smoking, divided by the total number of gaming staff man-hours. 3 The entity shall disclose the percentage of its gaming staff mandated by law to be stationed in a designated non- smoking area, calculated as the number of gaming staff who are mandated by law to be stationed for work in the casino’s designated non-smoking gaming facilities, divided by the total number of gaming staff. 8 Colorado State Smoking Ban (House Bill 08-1113). 9 Smoke Free Illinois Act (410 LLCS 82/). SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 13 Internal Controls on Money Laundering Topic Summary By the nature of its business, the Casinos & Gaming industry can be attractive to criminals seeking to launder money or disguise the origin of funds. Risk factors include the large amount of cash transactions, accessibility to multiple facilities, and customer anonymity. Therefore, strict and robust internal controls are necessary for companies to prevent violations of reporting and money laundering regulations. Casino operators that fail to detect and prevent money laundering activities may open themselves to investigations. Violations of anti-money laundering laws and regulations could result in criminal prosecution and/or substantial regulatory penalties. Accounting Metrics SV-CA-510a.1. Description of anti-money laundering policies and practices 1 The entity shall describe its policies and practices for assessing and managing money laundering risks internally as well as those associated with business partners in its value chain. 1.1 Relevant business partners include customers, suppliers, contractors, and subcontractors. 2 Relevant management practices include: 2.1 Barring cash-for-cash exchanges above a set threshold or for the purchase of casino checks 2.2 Conducting a risk assessment 2.3 Customer due diligence, including patron identification and verification and know-your-customer protocols 2.4 Employee awareness and training programs 2.5 Enforcing a cap on ticket-in and ticket-out redemptions at slot machine kiosks 2.6 Mechanisms for recordkeeping, reporting to government agencies (Financial Crimes Enforcement Network or others), and investigation of suspicious activities and red flags 2.7 Transaction monitoring 3 The entity may describe the implementation of one or more of the following: 3.1 American Gaming Association (AGA) Best Practices for Anti-Money Laundering Compliance 3.2 AGA Code of Conduct for Responsible Gaming SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 14 3.3 e-CFR “Know Your Customer” Guidance 3.4 Financial Action Task Force (FATF) Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion 3.5 FATF Guidance on the Risk-Based Approach for Casinos 3.6 U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) Guidance on Preparing a Complete & Sufficient Suspicious Activity Report Narrative 3.7 FinCEN Suspicious Activity Reporting Guidance for Casinos 4 The entity may describe the effectiveness of its programs and practices and any associated outcomes, including but not limited to: 4.1 Third-party auditing of the casino’s overall program 4.2 The number of customers who have undergone due diligence procedures 4.3 The number and types of due diligence reports performed 4.4 The number of Suspicious Activity reports filed to FinCEN SV-CA-510a.2. Total amount of monetary losses as a result of legal proceedings associated with money laundering 1 The entity shall disclose the total amount of monetary losses it incurred during the reporting period as a result of legal proceedings associated with money laundering. 2 The legal proceedings shall include any adjudicative proceeding in which the entity was involved, whether before a court, a regulator, an arbitrator, or otherwise. 3 The losses shall include all monetary liabilities to the opposing party or to others (whether as the result of settlement or verdict after trial or otherwise), including fines and other monetary liabilities incurred during the reporting period as a result of civil actions (e.g., civil judgments or settlements), regulatory proceedings (e.g., penalties, disgorgement, or restitution), and criminal actions (e.g., criminal judgment, penalties, or restitution) brought by any entity (e.g., governmental, business, or individual). 4 The scope of monetary losses shall exclude legal and other fees and expenses incurred by the entity in its defense. 5 The scope of disclosure shall include, but is not limited to, legal proceedings associated with the enforcement of relevant industry regulations, such as: 5.1 Anti-Money Laundering Law of the People's Republic of China SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 15 5.2 U.S. Bank Secrecy Act 5.3 U.S. Foreign Corrupt Practices Act Note to SV-CA-510a.2 1 The entity shall briefly describe the nature (e.g., judgment or order issued after trial, settlement, guilty plea, deferred prosecution agreement, or non-prosecution agreement) and context (e.g., improper recordkeeping) of all monetary losses as a result of legal proceedings. 2 The entity shall describe any corrective actions it has implemented as a result of each incident. This may include, but is not limited to, specific changes in operations, management, processes, products, business partners, training, or technology. SUSTAINABILITY ACCOUNTING STANDARD | CASINOS & GAMING | 16 SUSTAINABILITY ACCOUNTING STANDARDS BOARD 1045 Sansome Street, Suite 450 San Francisco, CA 94111 415.830.9220 info@sasb.org sasb.org