POLITICAL CONTRIBUTIONS POLICY
WYNN RESORTS, LIMITED
Political Contributions Policy and Procedures
Amended November 2, 2015
Wynn Resorts, Limited (“Wynn Resorts” or “Company”) operates and maintains interests in various jurisdictions across the United States and around the world. As such, the decisions of foreign, federal, state, and local governments affect the Company on a daily basis. Proposals to change existing laws or enact new laws and policy initiatives can impact the Company’s business and, in turn, affect its employees, surrounding communities, and stockholders.
Wynn Resorts takes earnestly its role as a good corporate citizen, placing highest priority on full compliance with all local, state, and federal requirements associated with participating in the policy-making and political processes. Compliance entails reporting to the Federal Election Commission (FEC) on receipts and disbursements from the company’s political action committee (PAC), as well as all other applicable reporting and registration requirements for activity in various jurisdictions.
Pursuant to the Company’s Code of Business Conduct and Ethics, Wynn Resorts strictly forbids giving or promising anything of value to a government official or government agent to avoid any appearance of influencing that person in his or her official duties or encouraging unlawful conduct.
Process and Oversight
Wynn Resorts conducts extensive and ongoing research when identifying quality candidates it may support for public office. The Company’s government affairs team meets regularly with individual candidates and incumbents to determine their familiarity with and stance on relevant issues of importance to the Company and its operations. Political contribution considerations are subject to an internal review process designed to confirm compliance with applicable law and to confirm that all political contributions are to promote the business interests of the Company.
U.S. Federal Elections
Wynn Resorts participates in U.S. federal elections through our PAC as well as via direct and in-kind contributions to national PACs. The Company’s government affairs team oversees the administration of our PAC, including assigning a registered Custodian of Records. In conjunction with this oversight, our PAC contributions are subject to an internal review process; with internal controls designed to comply with federally mandated contribution limits and regulations.
U.S. State and Local Elections
Races for non-federal offices are governed by state and local law, in addition to federal law. In making political contributions, Wynn Resorts’ policy is to strictly adhere to, and diligently comply with, the laws of each applicable jurisdiction. Political contributions (including direct or indirect payments of corporate funds to any political party, candidate or campaign, contributions by PACs funded by employee donations, contributions to social welfare and political organizations, and trade association dues) may be made only if permitted under applicable law.
An Affiliate of the Company was awarded a gaming license in the Commonwealth of Massachusetts in November 2014. Massachusetts law prohibits any individuals or entities licensed (or required to be licensed) by the Massachusetts Gaming Commission from making political contributions (cash or in kind), direct and indirect, to candidates for public office in Massachusetts, their committees or other political committees (other than a ballot question committee) above certain thresholds. The foregoing restriction does not apply to contributions made to the federal account of a political party committee or to any other federal political committees. Wynn Resorts’ policies are designed to confirm compliance with these prohibitions.
Employee Political Contributions
Wynn Resorts encourages employees to participate actively in community, civic, and political affairs. Wynn Resorts employees who choose to make political contributions may not be reimbursed in any manner by the Company. Eligible Wynn employees are permitted to make individual contributions to our PAC, but there are no contribution requirements as a condition of employment or any other job-related benefit.
From time to time, Wynn Resorts pays annual membership dues to industry trade associations, including the American Gaming Association (AGA) and the Nevada Resort Association (NRA), both of which represent an array of professional and industry interests. The trade associations in which the Company participates may engage in lobbying activities, decisions which are governed by those associations’ respective bylaws.