Welcome to our Code of Conduct, a cornerstone of our company’s ethical framework. This is more than just a policy; it represents our commitment to maintaining the highest standards of integrity, behavior, respect, and professionalism in everything we do.

As we navigate the dynamic and fast-paced world of the casino industry, this Code of Conduct will serve as our compass, ensuring that we remain true to our core values and principles. It is vital that each one of us understands and adheres to these guidelines, not only to protect our reputation but also to foster a culture of trust and transparency.

Sincerely,

Per Jaldung

CEO Grand Casino Brussels (GCB)

1. PURPOSE

This Code of Conduct (CoC) presents the fundamental ethical principles that must be implemented in professional practices and behaviors of our collaborators towards all stakeholders.

It serves as a guide for employees to navigate ethical dilemmas, recognize and address ethical risks, and foster a culture of transparency and integrity. It provides clarity on expected behaviours, mechanisms for reporting unethical conduct, and reinforces the importance of ethical decision-making.

Our commitment to integrity means adhering to all applicable laws, company policies, and procedures. It entails conducting ourselves honestly, treating others with respect and courtesy, and striving to enhance the reputation of Grand Casino Brussels (hereafter GCB) as a trusted and reputable organization.

The company's commitment to upholding the highest standards of business ethics and personal integrity is fundamental to Casinos Austria International's longstanding tradition. At GCB, each employee plays a pivotal role in safeguarding the reputation and integrity that are essential to our success.

In case of breaches of the CoC, an investigation starts and a potential sanction will be executed following the rules described in the Company Labor Regulations.

2. APPLICATION OF THE CODE OF CONDUCT

It is everyone's responsibility to comply with this CoC and all applicable laws and regulations.

Compliance with laws, regulations, and internal policies is non-negotiable at GCB. As an employee, you are expected to familiarize yourself with and adhere to all applicable legal and regulatory requirements governing casino operations.

This includes, but is not limited to, gaming regulations, anti-money laundering laws, employment laws, and health and safety regulations. Ignorance of the law is not an excuse, and failure to comply with legal requirements may result in severe consequences for both you and the casino.

Every employee of GCB is entrusted with the responsibility of conducting GCB business with unwavering integrity at all times. Upholding ethical standards is not only a requirement but a cornerstone of our corporate culture, emphasizing honesty, accountability, and respect in all interactions. Use this document as a set of guidelines for how you conduct your business, and consult it if you have any questions about your day-to-day activities.

All stakeholders have the duty to behave in accordance with this CoC on a daily basis. The term ‘stakeholders’ refers to all employees, irrespective of where they are located (i.e. people working at all levels and grades inside of the company, including senior managers, executives, directors, permanent, fixed term, and temporary employees, interns, seconded staff, homeworkers, casual and agency workers or volunteers).

This CoC also applies to all those doing business on behalf of GCB, such as agents, distributors, joint venture partners, consultants, and other third party intermediaries.

We expect everyone to commit in their agreements with GCB to respect the principles of our CoC, as well as the applicable laws and regulations in the countries where they operate.

If you are still unsure of how to proceed, contact your manager, the Compliance Department or HR Department.

3. GENERAL RULES OF CONDUCT

3.1 Respect and ethics

Politeness and respect: Behave courteously and respectfully towards customers, colleagues and superiors.

Confidentiality: Not divulging confidential information about customers, casino operations, or security policies.

Integrity: Respecting the rules of the game, avoiding any fraudulent behaviour or behaviour likely to damage the casino's reputation.

3.2 Appearance and Presentation

Uniform: Wear the casino uniform in accordance with current guidelines, and maintain a neat appearance.

Personal hygiene: Maintain impeccable personal hygiene.

Identification badges: Always wear identification badges visibly during working hours.

3.3 Customer relations

Welcome: Greet customers warmly and answer their questions respectfully and professionally.

Neutrality: Never favour a customer or show partiality in games of chance.

Respecting the limits of intervention: Not interfering in a customer's game unless necessary or requested to do so.

3.4 Use of Equiment and Resources

Casino equipment: Use equipment in a professional manner, without abuse or personal use.

Security systems: Comply with instructions relating to surveillance and security systems, and do not compromise security protocols.

4. SPECIFIC RULES ON CONDUCT

4.1 Gambling and Gambling interactions

Gambling prohibition: Employees are not permitted to gamble or bet in the casino.

Cash handling: Cash must be handled with care and never misappropriated for personal use.

Reporting suspicious behaviour: Report any suspicious behaviour or attempted fraud to the Security Service or to management.

4.2 Alcohol and drugs

Prohibition on alcohol consumption: It is forbidden to consume alcohol during working hours, except at events specifically approved by management.

Drugs and illegal substances: Any possession or consumption of illegal substances is strictly prohibited.

Effects of alcohol and drugs: Never report to work under the influence of alcohol or drugs.

4.3 Employees relations

Harassment and discrimination: Refrain from any harassing or discriminatory behaviour towards colleagues or customers.

Conflicts of interest: Declare any personal relationship or situation that may represent a conflict of interest within the casino.

Respect for hierarchical directives: Follow the instructions of hierarchical superiors and respect the rules for escalating problems.

5. ALIGNMENT & SCOPE

5.1 Alignment with Company Policies

While the CoC articulates our commitment to integrity, it is not intended to supersede or contradict existing company policies or procedures. Instead, it complements these guidelines, offering a comprehensive framework for ethical conduct applicable to both GCB personnel and all Casinos Austria International affiliates.

5.2 Application of Standards

The standards outlined in this CoC serve as guiding principles in our daily work, ensuring that we consistently prioritize ethical behaviour and uphold our responsibilities. These standards are integral to maintaining the trust and respect of our stakeholders.

5.3 Scope of Application

The standards of conduct apply universally to all employees, partners, officers, and board members of GCB, as well as to temporary service workers and independent contractors. Regardless of role or position, each individual is expected to adhere to these ethical standards.

5.4 Ethical Conduct Towards Patrons and Colleagues

We uphold the highest standards of ethical conduct in all interactions with Patrons and among colleagues. This commitment extends to our daily decision-making processes and reflects our dedication to legal and ethical responsibilities.

5.5 Expectations of Third Parties

We also hold third parties working on behalf of GCB to the same high ethical standards that we uphold internally. We expect our partners, suppliers, and vendors to conduct themselves with integrity and adhere to the principles outlined in this CoC.

6. ANTI-CORRUPTION [*1]

GCB is committed to maintaining the highest standards of integrity and ethics. Our collaborators shall not engage in bribery, whether directly or indirectly through intermediaries like agents or consultants. We strictly prohibit offering, promising, giving, accepting, receiving, or seeking bribes to gain advantages for oneself or GCB.

GCB also emphasize transparency in financial transactions:

• The use of cash for payments related to invoices, commissions, … towards suppliers is discouraged. Furthermore, all business partners must be properly registered in our financial systems.
• Legitimate business expenses, such as hospitality and promotional expenses, are accepted after approval as part of standard business conduct. The procedure of the expense note should be followed.
• We do not allow direct financial contributions to political candidates, parties, or campaigns using company resources. Any indirect contributions through third parties must be reported and approved.
• Charitable donations, whether in financial or in-kind form, must receive pre-approval from senior management. We maintain transparency and thoroughly evaluate potential conflicts of interest in this regard.
• Sponsorship agreements must align with our company values and objectives and require approval from senior management. Compliance with all relevant laws and regulations is mandatory.

6.1 Fair Gaming

Integrity and fairness are fundamental principles of casino gaming. As an employee of GCB, you are entrusted with ensuring that all games are conducted honestly and ethically. This means refraining from any form of cheating, collusion, or manipulation that could compromise the integrity of the gaming experience.

Additionally, it is essential to remain vigilant and promptly report any suspicious behavior or irregularities observed during or outside gaming operations. This means that during as well as after the regular working hours our employees should remain ethically correct. This includes instances of cheating or fraud by patrons, as well as any concerns regarding the conduct of fellow employees.

By upholding the principles of fair gaming, you help maintain the trust and confidence of patrons in the integrity of GCB's gaming offerings.

7. ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM

It is embedded into our daily business conduct that we want to prevent transactions with a criminal background and help detect and combat them. This applies particularly to transactions that serve the purpose of laundering money or financing terrorism.

To best achieve the goal of preventing and combating money laundering and terrorism financing, GCB takes all necessary measures. These include, for example, comprehensible risk analyses, regular internal audits of the systems implemented, and cooperation with competent authorities.

In cases of doubt about any financial transaction, our employees must consult their supervisor or directly the company's money laundering reporting officer.

8. RESPONSIBLE GAMING

GCB is committed to promoting responsible gaming practices and ensuring the well-being of all patrons. As an employee, you play a crucial role in identifying and addressing potential issues related to problem gambling.

Be attentive to signs of excessive or compulsive gambling behavior among patrons, such as significant financial losses, or changes in behavior. Approach patrons with sensitivity and compassion, offering assistance and resources to help them make informed decisions about their gambling habits.

Furthermore, it is essential to adhere to all responsible gaming policies and procedures established by GCB, including self-exclusion.

If you encounter a patron who may be experiencing difficulty with gambling addiction, refer them to appropriate support services, such as counselling helplines or community organizations specializing in gambling addiction treatment. GCB refers to the website of the Gaming Commission where more information and instructions can be found to protect the patrons and keep on responsible gaming: https://www.gamingcommission.be/en/protection-of-players

By promoting responsible gaming practices, you demonstrate GCB's commitment to social responsibility and the well-being of our patrons and the community at large.

9. ANTI-DISCRIMINATION

We all deserve to work in an environment where we are treated with dignity and respect. GCB is committed to creating such an environment because it brings out the full potential of each of us, which in turn directly contributes to the success of our business.

GCB is an equal-opportunity employer that values diversity and inclusion within its organization. The recruitment process is therefore not based on sex, disability, family status, sexual orientation, age, political opinions, religious beliefs, trade union activity, or racial, social, cultural, or national origins. Behaving ethically means not engaging in discriminatory practices.

The recruitment procedure and evaluation forms are made to exclude any type of bias.

When suspecting any type of discrimination, we encourage our employees to speak up. In first instance towards the manager, the manager of the manager or the HR Department. In case this is not working out, we refer our employees to the ‘Whistleblowing Policy’ which is published on the communication platforms.

At GCB, we embrace diversity and inclusion as essential principles that enrich our workplace culture and strengthen our organization. We recognize and value the unique perspectives, backgrounds, and experiences that each employee brings to the table.

As an employee, you are expected to treat all individuals with dignity, respect, and fairness, regardless of their race, ethnicity, gender, sexual orientation, religion, age, disability, or any other characteristic.

Discrimination or intolerance of any kind will not be tolerated within our organization.

Furthermore, we are committed to creating an inclusive work environment where everyone feels valued, empowered, and able to contribute their best work. This includes actively seeking out and listening to diverse voices, perspectives, and ideas, and ensuring that all employees have equal opportunities for advancement and professional growth.

By fostering diversity and inclusion, we not only enhance employee morale and engagement but also better serve the needs and preferences of our diverse patron base. Together, we celebrate our differences and strive to build a workplace culture that is welcoming, inclusive, and respectful of all individuals.

10. ANTI-HARASSMENT

Since GCB operates in a global and multicultural setting, we firmly think that diversity is a significant advantage. Because of this, every employee needs to adopt a mindset that values every person, regardless of whether they work for our organization or not.

We respect every person’s rights, privacy, and sense of personal dignity. At GCB we forbid employees to harass someone because of their age, gender, nationality or ethnicity, religion, political beliefs, sexual orientation, handicap, or any other legally protected characteristic.

Any employee who feels harassed must report the incident to their manager. When suspecting any type of harassment we encourage our employees to speak up. In first instance towards the manager, the manager of the manager or the HR Department. In case this does not work, the employee can go to the internal person of confidence and in a later stage to the external person of confidence. Besides that, we refer our employees to the ‘Whistleblowing Policy’ which is published on the communication platforms.

11. HUMAN RIGHTS

We are committed to respecting the human rights of our employees or persons acting on our behalf, as well as those of our Patrons, suppliers, and other business partners, in accordance with the United Nations guidelines on business and human rights.

11.1 Fight against child Labor

At GCB we only employ people who meet the local minimum age requirements. In addition, we follow the relevant ILO conventions, which ensure that children are only employed when they are fully protected from potential exploitation, protected from health risks, and allowed to continue their education.

11.2 Fight against forced labor

We fight against forced labor. Employment must be voluntary and freely chosen.

12. HEALTH AND SAFETY

At GCB, we are committed to maintaining a safe and healthy working environment for our employees, visitors, and contractors. We all share responsibility for making safety and health a daily priority.

Our employees are encouraged to raise any concerns about health and safety risks or unsafe working conditions and to report accidents and work-related situations promptly.

We implement preventive measures and take timely corrective action when we become aware of an unsafe or dangerous situation.

GCB takes the safety of its employees seriously and created a special e-mail address (incident@viage.be)” which all employees can use. This email address has been created as a way to directly report incidents involving interactions with Patrons and staff, or problems our employees encounter with the facilities or equipment, that could not be first resolved through the Manager/Department Head. These incidents will be investigated impartially and the appropriate actions taken. The employee will receive feedback on the report.

Externally, GCB is collaborating with the City and the Police to enhance safety around the casino premises. Internally, GCB has intensified the efforts to strengthen security measures and improve standards of conduct.

In pursuit of this objective, GCB has the “Membership Agreement” which all Patrons are required to abide by upon entering the casino. With the help of a strict "zero-tolerance" policy, whereby any acts of vandalism towards equipment or facilities, incidents of physical aggression, or persistent abuse or harassment towards our employees or fellow patrons will result in an immediate barring.

With the “Membership Agreement” extract GCB reserves the right to deny access to anyone who conveys the impression that they may disrupt the calm and orderly functioning of the casino, or who could prevent a fair and honest game.

In cases of vandalism or willful damage the Member is expected to make full restitution for the damages caused before a lifting of the ban will be considered.

13. WORK CONDITIONS

GCB ensures that all its employees are in compliance with local laws and standards set by the industry with respect to the numbers of working hours and working days. Employees engage in reasonable daily and weekly work schedules with appropriate rest periods provided for.

The work-life balance is guaranteed by the Belgian CLA ‘Workable Work’ and applied in a GCB CLA.

GCB is committed to providing the conditions for a good work-life balance. If a situation within GCB upsets your balance, it is essential that you talk to your manager in order to identify the causes and put in place the conditions necessary for a good balance.

14. DATA PROTECTION

GCB is committed to protecting the confidential information of its Patrons, employees, and suppliers and is subject to a duty of confidentiality. We comply with the European regulation on the protection of personal data [*2] (GDPR).

GCB collects, uses, stores, or processes your personal data in accordance with the GDPR [*3] and any replacement legislation, or any similar regulation under any applicable law, and any regulatory requirements or codes of practice governing the use, storage, or transmission of personal data.

Thus, in accordance with the GDPR, GCB disposes of your personal data on the following legal grounds:

• On the basis of the execution of the contract agreed upon with the Patron or the execution of pre-contractual steps taken at the request of the Data Subject.
• On the basis of compliance with legal or regulatory provisions with regard to the management of the contractual relationship with the Patron, invoicing in particular.
• On the basis of our legitimate interest in responding to information requests from Visitors and Patrons.
• On the basis of the explicit consent.

In accordance with these regulations, GCB reserves the right to use your data, provided that they are up to date and processed only as long as necessary to achieve the company’s objective or as required by law.

Respect for confidentiality ensures the maintenance of trusting relationships with its various stakeholders.

15. COMPANY PHILOSOPHY ON OUR STAKEHOLDERS

15.1. The Patron

At GCB, we place utmost importance on providing exceptional Patron service to all patrons. As an employee, you are expected to uphold the highest standards of professionalism, courtesy, and respect in all interactions with patrons.

15.1.1. Confidentiality

Protecting the privacy and confidentiality of patron information is of utmost importance at GCB. As an employee, you are entrusted with access to sensitive data, including personal information and financial records of patrons.

It is imperative to handle this information with the utmost care and discretion, ensuring that it is only accessed and disclosed on a need-to-know basis for legitimate business purposes. This includes adhering to established protocols for handling and storing confidential information securely.

Under no circumstances should patron information be shared or disclosed to unauthorized individuals or third parties. Any breaches of confidentiality must be reported immediately to the appropriate management or compliance personnel for investigation and resolution.

By maintaining the strictest standards of confidentiality, you demonstrate your commitment to protecting the privacy rights of patrons and upholding the reputation of GCB as a trusted custodian of sensitive information.

15.1.2. Honesty and Integrity

Integrity is the cornerstone of professional conduct at GCB. As an employee, you are expected to act with honesty, integrity, and transparency in all your dealings, both within the organization and with external parties.

This includes being truthful and forthcoming in your communications, adhering to all applicable laws and regulations, and conducting yourself in a manner that upholds the highest ethical standards at all times.

Avoid conflicts of interest that may compromise your judgment or impartiality in decision-making processes. This includes refraining from engaging in any activities or relationships that could create a perception of bias or impropriety.

Additionally, be vigilant against bribery, corruption, or other forms of unethical behaviour. Report any instances of misconduct or violations of the CoC to the appropriate authorities for investigation and resolution.

By embodying honesty and integrity in your actions and decisions, you uphold the reputation and trustworthiness of GCB as a reputable and ethical organization.

15.2. The Employee

At GCB, we hold a deep commitment to defining and aligning the roles and responsibilities of our employees. This section of our CoC serves as a structured framework, guiding all team members towards effective collaboration and contribution to our collective success. Here, we outline our philosophy regarding job duties and responsibilities, emphasizing clarity, adherence to regulations, and dedication to Patron service excellence.

Every sentence below starts with 'The employee':

15.2.1. General Responsibilities

• Carries out his/her duties for the GCB by following internal procedures and conforming to internal company regulations, as well as all laws and regulations of the Gaming Commission.
• Respects security regulations regarding all transactions and/or handling of money, chips, tokens, keys, and codes.
• Is aware of all security risks and knows all the procedures in case of security issues.
• Continues to attend training sessions and courses organized by GCB to carry out duties productively and efficiently, ensuring the profitability of the company.
• Bears him/herself in a correct and proper manner at all times.
• Must carry out his/her duties while respecting internal rules and regulations of GCB.
• Must never and in no circumstances discuss or act against instructions given.
• Must carry out his/her duties in a correct and professional manner.
• Must always possess a D-license.
• Must refrain from visiting other casinos within Belgium.
• Must rigorously carry out all laws and directives of the Gaming Commission.
• Must ensure that any dishonest behaviour and sexual harassment are prevented. Any offenses must be reported to the management team.

15.2.2. Patron Oriented

• Wears and cleans the uniform following the uniform policy.
• Must immediately alert the members of the Casino Management in the event of a major problem with patrons.
• Must immediately alert the members of the Casino Management of any suspicious behaviour (problematic players, money laundering, etc.).
• Must immediately advise his/her superiors of any attempts at contact made by patrons either within or outside of the GCB.
• Respects the privacy of patrons.
• Respects professional secrecy.

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[1] Corruption is the conduct by which a person (public or private) proposes, requests or accepts directly or through an intermediary, a gift, offer or promise, gift or benefit of any kind to accomplish, to delay or omit to perform an act of direct or indirect consequence in the course of his duties in order to obtain or retain a commercial or financial advantage, to influence a decision.

[2]Personal data means any information relating to a natural person who can be identified, directly or indirectly, in particular by reference to a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. 

[3] In this Code of conduct, the ‘GDPR’ is a reference to the Regulation of 27 April 2016 on the Protection of Natural Persons with regard to the Processing of Personal Data and on the Free Movement of such Data (General Data Protection Regulation).