At NYRA we are committed to creating an environment where employees feel comfortable raising concerns about potential workplace wrongdoing. NYRA requires directors, officers and employees to maintain high standards of business and personal ethics when performing their duties and responsibilities and comply with all applicable laws and regulations.
This Whistleblower Policy is intended to encourage and enable employees and others to raise and report serious concerns internally so that NYRA can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, and employees to report serious concerns about violations of NYRA’s Code of Ethics, internal policies or suspected violations of law or regulations that govern NYRA’s operations. The subject matter of any report includes, but is not limited to, violations of federal, state or local laws or regulations applicable to NYRA; any cases of fraud, corruption, misapplication or deliberate misconduct in connection with NYRA’s business or the preparation of its reports or any violation of any of NYRA’s policies.
It is contrary to the values of NYRA for anyone to retaliate against an employee who in good faith reports a potential ethics violation, or a suspected violation of law. Potential concerns may include a report of discrimination, suspected fraud, or an undisclosed conflict of interest. A director, officer or employee who retaliates against someone who has reported a violation in good faith is subject to corrective action up to and including termination of employment or removal from office for cause.
NYRA has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with your Human Resources representative or any member of the Legal Department.
If you are uncomfortable raising a concern with any of these internal resources you may also report anonymously to NYRA’s Compliance & Ethics Hotline by dialing:
Reports received about potentially unethical or illegal conduct will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
NYRA’s Chief Corporate Compliance Officer is responsible for ensuring that all reports about corporate unethical or illegal conduct are investigated and resolved and maintaining a record of each such report. NYRA’s Steward is responsible for ensuring that all reports about equine or racing related unethical or illegal conduct are investigated and resolved and maintaining a record of each such report. The Steward will advise the Chief Corporate Compliance Officer of all reports and their resolution.
Violations or suspected violations may be reported on a confidential basis by any individual. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Accounting and Auditing Matters
Reports received or concerns about corporate accounting practices shall be promptly reported by the Chief Corporate Compliance Officer to the Finance and Audit Committee. NYRA will work with the committee until the matter is resolved.
Acting in Good Faith
Anyone making a report concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
Provisions of this Policy Supersede any Contrary Agreement or Policy
The provisions of this Policy extend to each agreement or other policy of NYRA. Any provision in any agreement by NYRA that requires confidentiality of information to the extent that such provisions may impede the action of any of NYRA’s directors, officers and employees to make a report as described above under “Reporting Procedure” or to fully cooperate with any investigation of any violation or suspected violation is hereby irrevocably waived by NYRA.
Amendments or Updates
This Policy could not, and is not intended to, address every possible situation that may arise. Each person is responsible for conducting themselves lawfully and ethically in all of their business dealings, for reporting any unlawful and/or unethical conduct, and for seeking further guidance when in doubt.
This Policy will be amended or supplemented from time to time in the determination of the NYRA Board of Directors or the Finance and Audit Committee of the board. The current terms of this Policy shall be maintained in the Employee Handbook or a supplement provided to the employees and/or on the Company’s website.
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