Mohegan has established Management Board level seats on our Compliance and Audit Committees to ensure an open communication channel with the Management Board and supports a culture of compliance throughout the organization .
• Whistleblower Program : Mohegan operates a formal whistleblower program for anonymous , independently proctored , reporting at all properties under the oversight of our Audit and Compliance Committees .
• Anti-Money Laundering ( AML ): U . S . properties follow American Gaming Association ( AGA ) guidelines for best practices and training for team members . Niagara Casinos collaborate with provincial police on-site for investigations . Mohegan also annually conducts company-wide training and independent auditing of AML compliance .
• Harassment and Discrimination : Mohegan has an enterprise-wide policy regarding harassment and discrimination and requires regular ( annual or bi-annual based on the property ) training for supervisors and above .
• Code of Ethics / Conduct : Mohegan requires regular ( annual or bi-annual based on the property ) training for supervisors and above , with certain compensation tied to the completion of all training .
• Internal Audit : Mohegan has ongoing internal auditing capabilities at all operational properties with direct reporting to the Audit and Compliance Committees .
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