Highlights
Highly experienced management team and accomplished, diverse Board of Directors
Composition of the Audit Committee, Compensation Committee and Nominating and Governance Committee of our Board of Directors
Organizational documents, Committee charters and other governance documents
OUR KEY OBJECTIVES AND APPROACH
Our key corporate governance objectives and approach are set forth in three pillars:
- ESG Oversight and Risk Management – Maintain effective ESG oversight and risk management as a passive real estate owner and as appropriate given our status as a triple-net lessor
- Reporting and Strategic Integration – Enhance our internal framework, processes, and controls to continue progressing our ESG reporting capabilities and integrating ESG considerations into our investment, business, and asset management strategies
- Stockholder Value Creation – Continue our commitment to maintaining the highest standards of corporate governance in promoting long-term value creation, transparency, and accountability to our stockholders
Stakeholder Engagement
We actively engage our primary stakeholders through a comprehensive annual stakeholder engagement program as well as regular, informal communication as circumstances warrant. Our primary stakeholders include our stockholders, our employees, our tenants and borrowers, and our communities, including those in which our properties are located, and our engagement is tailored to each group, as applicable, and may include one-on-one communication, investor conferences, discussions relating to performance, business initiatives and contractual considerations, and further development of our ongoing partnerships. Stakeholders are also encouraged to engage with the Company directly through outreach to our investor relations team, our legal department, our finance and investor relations team and our human resources team.
Enterprise risk management
Our Enterprise Risk Management (“ERM”) framework is premised on actively monitoring the Company’s risk profile; ensuring the involvement of management, the Board of Directors and key employees in evaluating and addressing risk; and maintaining effective policies, controls and procedures to manage risk and pursue our strategic priorities.
Compliance Program
Our officers, employees and directors are responsible for being aware of and complying with the corporate policies applicable to their activities. All of our team members also have a duty to report any actual or perceived misconduct through appropriate management channels, or confidential reporting mechanisms which have been established within the Company for such purposes, and to assist the Company in the prevention and correction of such misconduct. Team members are encouraged to talk to supervisors, managers or other appropriate personnel about observed illegal or unethical behavior and team members are encouraged report this conduct violating these policies to the Company. The Company maintains a strict policy that no supervisor shall retaliate against an employee, either directly or indirectly, against team members, who in good faith and in accordance with Company procedure, report an act of actual or perceived misconduct. Team members are also expected to cooperate fully with the Company or governmental authorities in any investigations of misconduct . Failure of any officer, employee or director to comply with such policies will result in disciplinary action, which may include termination.
Whistleblower Policy
The Company encourages all of its officers, employees, directors and other stakeholders to speak with management, supervisors or other appropriate personnel regarding any apparent misconduct or violations of our policies. In addition, we partner with an unaffiliated vendor to monitor a confidential and secure online and telephonic reporting structure whereby our employees may report any concerns. Concerns may be submitted via the internet, via hotline, to the legal department directly by email or by speaking directly to a member of the management team. The Company does not permit retaliation against any employee who, in good faith, and in accordance with our procedure, reports any act of apparent misconduct.
See the Company’s Whistleblower Policy for more information on the reporting of illegal or unethical behavior about improper or questionable accounting, internal accounting controls and auditing matters involving the Company.
Political Engagement
We encourage our employees to participate in political activities on their own time and at their own expense, and in a manner consistent with applicable law and our applicable policies. We have adopted a Political Contribution Policy setting forth internal safeguards to prevent unlawful political contributions by the Company and its officers, employees and directors who are licensed or have applied for a gaming license in one or more of the jurisdictions in which the Company is licensed. Federal law and many state and local laws prohibit corporate contributions to political parties or candidates. Company assets, facilities and resources may not be used for political purposes except in accordance with law and after approval by the Board of Directors.
We are a member of certain industry associations, including the National Association of Real Estate Investment Trusts (Nareit) and the American Gaming Association, and a portion of the membership dues we pay to these organizations may be allocated by these organizations to certain lobbying and political activities.
Cybersecurity
Cybersecurity impacts various aspects of our business, including our operations, governance, compliance program and employee training. Our team members regularly receive training on key issues, such as enterprise security, malware, anti-phishing and data protection best practices, as well as training with respect to our implemented information security measures. We are continuously engaging with external service providers and consultants to identify potential risks and proactively mitigate their potential impact, including through these training programs. As a component of our overall insurance coverage, we have separately obtained a standalone cybersecurity policy. Information security is also an element of the enterprise risk assessment periodically performed by management under the supervision of the Audit Committee of our Board of Directors. Our management team updates the Audit Committee and Board of Directors multiple times throughout the year with respect to key developments and updates relating to our cybersecurity measures and practices.