Sports Gaming Media LLC
Statement on Political and Trade Association Activity
Participation in political activities, whether done directly or through involvement with a trade association or other organization, is important to achieving the business objectives of Sports Gaming Media. It is also critical that all our activities in this area display rigorous compliance with applicable laws, regulations, and our own code of ethics. For this reason, Sports Gaming Media’s essential policy with respect to political activities is set forth in the Company’s Code of Conduct. This statement provides additional amplification on the Company’s implementation and compliance activities in connection with that basic policy.
Key Implementation Statements
- The primary responsibility for implementation of Sports Gaming Media’s political and trade association activities rests with the Company’s Political Activities Council (“PAC”) organization, which ultimately reports to the Company’s Executive Vice President (a direct report to our Chairman and CEO). The PAC organization operates throughout the business footprint of Sports Gaming Media and in Washington, D.C.
The political activities engaged in by the PAC organization include development and advocacy of public policy, lobbying, activity in a variety of trade associations, participation in several intergovernmental associations, and partnerships with other companies in the broadcast, cable, and satellite industry alongside third party organizations on public policy issues of concern to the Company. The work of the PAC team is regularly reported to senior management of the Company and to the board of directors.
- The political activities of the Company undertaken directly and through participation in a trade association are directed to influencing the wide variety of public policy issues that impact the Company’s business. These activities include supporting candidates who support issues of concern to the Company as well as issue and legislative advocacy. The issues include legislation and regulation relating to the distribution of video content over our uplink/downlink facility, local and state broadcasting laws and regulations, regulation of the Internet and Video-On-Demand services, and a variety of general legislative and regulatory initiatives that affect Sports Gaming Media as a business, including tax, labor, and workplace safety issues.
- Requests for corporate and political action committee are made by members of the PAC organization, or by business leaders of the Company, through a member of the PAC organization. All such requests are reviewed pursuant to a rigorous process and all contributions are ultimately approved by the Vice President of Administration and the Executive Vice President and reviewed by inside and/or outside legal counsel, as appropriate. None, IF any, financial contributions will be given in anticipation of, in recognition of, or in return for an official act. Management makes an annual report to the board of directors on the Company’s political activities, including all political contributions. The Governance and Directors Nominating Committee of the board, composed entirely of outside directors, is responsible for overseeing the company’s political activity and receives the annual report and periodically reviews this statement. As outlined in the Sports Gaming Media Code of Conduct, employees are also prohibited from causing such corporate or Super-PAC contributions without going through this vetting process. Employees are required to have gifts to, and entertainment of, government officials vetted in the same manner. Employees will not be reimbursed directly or through compensation increases for personal political contributions or expenses.
- Sports Gaming Media also participates in the activities of various trade organizations and chambers of commerce. The trade organizations are principally composed of cable industry associations and are operated for the purpose of advancing the common goals and interests of the member companies and their customers. Participation in all trade associations is subject to approval by the Executive Vice President. Sports Gaming Media will not pressure or coerce employees to make personal political expenditures or take any retaliatory action against employees who do not. These principles were completely adhered to in 2021.
- From a compliance perspective, first and foremost, the Company complies with all applicable laws and regulations concerning political contributions. We regularly consult inside and outside counsel to design and monitor our political activity compliance program. All, IF any, financial contributions are publicly disclosed as required by law, including disclosures required by federal law to the Federal Election Commission and comparable disclosure requirements in many states and localities.