At PENN Entertainment, our values are the foundation of the way we do business. They unite us under one set of shared beliefs. Most importantly, our values help us achieve our business objectives the right way—with integrity. Respect for human rights is a fundamental value of PENN Entertainment. We have a strong reputation of trust and respect.

PENN Entertainment operates its business in a socially responsible and ethical manner consistent with human rights principles. Our approach to human rights is guided by international standards -- we respect and support the UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises, core Conventions of the International Labour Organization (ILO), the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Universal Declaration of Human Rights. We are committed to embedding respect for human rights throughout all aspects of our business, partnerships and within the communities we touch. Additionally, we commit to engaging with stakeholders to understand their perspectives, improve our monitoring, analysis or remediation of human rights impacts, and better understand how to evolve our actions supporting this policy. Our Human Rights Policy is the cornerstone of all that we do. The Board of Directors has overall responsibility for overseeing compliance with this policy.

We seek to be a preferred place to work, where all are welcomed. The world is diverse in its social customs and cultural traditions, and we respect and embrace those differences for our guests, our Team Members and communities.

Our Principles 

Diversity, Non-Discrimination and Non-Harassment: We promote Diversity, Equity, Inclusion & Belonging of the people with whom we work. We are committed to equal opportunity and prohibit discrimination and harassment in our work environment based on any legally protected characteristic. We respect the rights of all Team Members and their culture, identity, traditions and customs and support reconciliation within PENN and in the communities in which we operate. We maintain a work environment that is free from discrimination or harassment on the basis of race, color, sex, national origin or ancestry, gender, gender identity, gender expression, transgender status, sexual orientation, religion, physical or mental disability, age, political opinion, pregnancy (including lactation, childbirth or related medical conditions), , ethnicity, caste, marital or family status, citizenship status, immigration status, genetic information (including testing and characteristics), veteran status, uniformed servicemember status, or any other characteristic protected by applicable law, regulation or ordinance. Our recruitment, hiring, placement, development, training, compensation and advancement at the Company is based on qualifications, performance, skills and experience regardless of protected characteristics.  We do not require, ask for money, or charge fees to the applicant as part of our hiring process. We respect the right to privacy and ensure that we collect, store and handle information. 

PENN Entertainment’s Equal Employment Opportunity policy covers all employment practices, including discipline and separation of employment.  All employment decisions are made without regard to an applicant or Team Member’s protected characteristics.

Harassment based on protected characteristics is not tolerated in the workplace and in any work-related circumstance outside the workplace, including business trips or company-sponsored social events. Prohibited behavior can be verbal, written, or physical, and it can take place on email, text message, or social media. Team Members should refer to the Company’s policy on Respectful Workplace; Prohibition on Discrimination or Harassment Policy for additional information.  If any of our Team Members experience, or witness, any behavior which they believe violates this policy or any other workplace policy (including retaliation), they can report it immediately so that it can be investigated promptly. There are several ways to make a report:

• Report to their management team;
• Report to Human Resources; or
• Report (anonymously, if they wish) to the PENN Entertainment Hotline (by calling the Company’s toll-free number at 1-877-864-9164 or via the internet at EthicsPoint - PENN Entertainment), which is monitored by PENN Entertainment’s Corporate Compliance Department.

No reprisal or retaliatory action will be taken against any Team Member for raising concerns under this policy. The Company will investigate, address and respond to the concerns of Team Members and will take appropriate corrective action in response to any violation.

This Policy should be read in conjunction with the Federal Compliance Policy (103) and Respectful Workplace; Prohibition on Discrimination or Harassment Policy (703).

Prevention of Human Trafficking, Forced Labor and Child Labor: The Company adheres to the UN Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children; The Trafficking Victims Protection Act of 2000, and the Modern Slavery Act of 2015. We do not tolerate the use of forced labor, or human trafficking in any form—including slave labor, prison labor, indentured servitude, bonded labor, or military labor. We also prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required -in our operations or supply chain.  Our commitment includes, but is not limited to the following:

• We do not tolerate illegal child labor, forced labor or any use of force or other form of coercion, fraud, deception, abuse of power or other coercive means to force people to perform services.
• All recruitment fees shall be paid by the employer, and not the individual.
• We do not use misleading or fraudulent practices during the recruitment of candidates/employees or offering of employment.
• All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment and no unreasonable restrictions on entering or exiting company-provided facilities.
• We will not hold or otherwise destroy, conceal, confiscate or deny access by employees to their identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law.

No reprisal or retaliatory action will be taken against any Team Member for raising concerns under this policy. The Company will investigate, address and respond to the concerns of Team Members and will take appropriate corrective action in response to any violation.

Workplace Health and Safety: The safety and health of our Team Members is of paramount importance. Our Team Members are our most valuable resource.  Our policy is to provide a safe and healthy workplace for both our Team Members and guests while complying with applicable safety and health laws, regulations, and our own internal standards. We work to provide and maintain a safe, healthy and productive workplace, in partnership with our Team Members, by addressing and remediating any identified risks of accidents, injury and health impacts. Please also see the Workplace Safety, Security & Accidents Policy (506).   

Working Hours: We compensate Team Members competitively relative to the industry and local labor market, and in accordance with terms of applicable collective bargaining agreements.  We work to ensure full compliance with applicable wage, work hours, overtime and benefits laws.  We do not require Team Members to work more than the maximum number of hours permitted under applicable laws. Working overtime is compensated appropriately based on applicable laws. Please also see the Team Member Relations Policy (102) and Timekeeping Policy (402). 

Freedom of Association: We uphold the labor standards including recognizing the right to freedom of association and collective bargaining, supporting the elimination of forced or bonded labor, human trafficking and child labor, and ensuring we provide fair pay and working conditions for all Team Members. We respect freedom of association and our Team Members’ right to join, form or refrain from joining or forming, third party organizations such as labor unions or other lawful organization of their own selection, along with the right to bargain or not bargain collectively, in accordance with the law, without fear of reprisal, intimidation, or harassment.  We are committed to fostering open communication between all Team Members and managers, regardless of whether they are in unions, and providing our Team Members with appropriate access to complaint procedures and remedial action.  Where Team Members are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their elected representatives. The Company is committed to bargaining in good faith with such representatives.

Environmental Fellowship:;Our commitment to the environment is embodied in our Environmental Policy. We strive to conserve energy, water, and other natural resources; and work to reduce the environmental impact of waste generation and emissions. We recognize that water is a critical natural resource and access to it is a fundamental human right. 

Workplace Security:  We are committed to maintaining a workplace that is free from violence, unlawful harassment, intimidation and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for Team Members are provided, as needed, and are maintained with respect for Team Member privacy and dignity. Please also see the Prohibition Against Harassment or Discrimination Policy (703), Workplace Violence Prevention Policy (522), and Work Conduct Rules & Discipline Policy (511). 

Empowering Women:  Historically, women have been underrepresented in the workforce and many women still today face discrimination and disadvantage, lack access to skills and training, and or other roadblocks to professional advancement. We recognize that women are integral to our business and communities. We endeavor to empower women by demonstrating respect for their contribution to our business and exploring opportunities to engage in professional development and eliminate systemic barriers to women’s advancement in the workplace. Please also see the Federal Compliance Policy (103) and Respectful Workplace; Prohibition on Discrimination or Harassment Policy (703).

Our Communities: For us, being a good corporate citizen means improving the lives of the people in the communities where we live and work. We invest heavily in our communities, providing funding and other support to a wide range of local and national causes. Our current efforts are focused on education, advancing diversity and inclusion, our veterans and members of the military (and their families), human dignity and environmental stewardship.

Disability Accommodation: PENN Entertainment will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or a Team Member, unless undue hardship and/or a direct threat to the health and/or safety of the individual or others would result. Any Team Member who requires an accommodation in order to perform the essential functions of their job, enjoy an equal employment opportunity, and/or obtain equal job benefits should contact their Human Resources department to request such an accommodation. Team Members who believe they need an accommodation must specify, preferably in writing, what barriers or limitations prompted the request. Human Resources will communicate with the Team Member and engage in an interactive process to determine the nature of the issue and what, if any, reasonable accommodation(s) may be appropriate.  In some cases, this interactive process may be triggered without a request from the Team Member, such as when the Company receives notice from its own observation or another source that a medical impairment may be impacting the Team Member’s ability to perform essential job functions. The Company will evaluate information obtained from the Team Member, and possibly the Team Member’s health care provider or another appropriate health care provider, regarding any reported or apparent barriers or limitations, and will then work with the Team Member to identify possible accommodations, if any, that will help to eliminate or otherwise address the barrier(s) or limitation(s). If an identified accommodation is reasonable and will not impose an undue hardship on the Company and/or a direct threat to the health and/or safety of the individual or others, the Company will generally make the accommodation, or it may propose another reasonable accommodation which may also be effective. Team Members are required to cooperate with this process by providing all necessary documentation supporting the need for accommodation and being willing to consider alternative accommodations when applicable. Qualified individuals with disabilities are entitled to equal pay and other forms of compensation (or changes in compensation) as well as job assignments, classifications, organizational structures, position descriptions, lines of progression, and seniority lists. 

Pregnancy Accommodation: In accordance with the federal Pregnant Workers Fairness Act (“PWFA”), the Company will make reasonable accommodations for known physical or mental limitations related to the pregnancy, childbirth or related medical conditions of a qualified applicant or Team Member, unless the accommodation would impose an undue hardship on the operation of the Company’s business. 

“Known physical or mental limitations” are those that the applicant, Team Member, or their representative has communicated to the Company. Team Members or applicants who wish to inform the Company of such a limitation and/or request a reasonable accommodation under this policy should contact their Human Resources department preferably specifying in writing, what barriers or limitations prompted the request. The Company will evaluate information provided regarding any reported or apparent barriers or limitations and will then communicate with the applicant or Team Member and engage in an interactive process to determine the nature of the limitation and what, if any, reasonable accommodation(s) may be appropriate. If, through this interactive process, the Company and the individual arrive at a reasonable accommodation that does not impose an undue hardship on the operation of the Company’s business, the Company will make that accommodation.

Team Members who wish to request time away from work to accommodate a limitation related to pregnancy, childbirth or a related medical condition should contact their Human Resources department. However, the Company will not require a qualified Team Member to take leave if another reasonable accommodation can be provided.

A number of states and localities have laws that apply to employees affected by pregnancy, childbirth, or related medical conditions. For Team Members in a jurisdiction that has a mandatory pregnancy accommodation law, the Company will comply with all legal requirements, including providing greater or different benefits than those indicated here.

Illnesses in the Workplace: Any Team Member who suspects they may have an infectious or contagious condition or communicable disease that could be of potential danger to a customer or co-workers, should not report to work.  For purposes of this policy, communicable diseases and communicable illnesses include, but are not necessarily limited to, tuberculosis, contagious herpes simplex virus-related diseases such as chicken pox, shingles, infectious mononucleosis, hepatitis B, severe acute respiratory syndrome (SARS), monkeypox, West Nile virus, COVID-19 and pandemic flu. Each case of communicable illness and communicable disease exposure is different and will, therefore, be treated according to the individual facts and circumstances on a case-by-case basis.

The Company will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or a Team Member, unless undue hardship and/or a direct threat to the health and/or safety of the individual or others would result.

Medical information on any Team Member is confidential. The Company will take reasonable precautions to protect medical information from inappropriate disclosure. No medical information will be maintained in a Team Member’s personnel file. Managers and other Team Members have a responsibility to respect and maintain the confidentiality of Team Member medical information. Anyone inappropriately disclosing medical information is subject to disciplinary action, up to and including separation of employment