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Marketing & Advertising Code

CAESARS ENTERTAINMENT CORPORATION

MARKETING AND ADVERTISING CODE

(June 2019)

Introduction

Each year, millions of responsible adults enjoy the excitement of gambling at properties owned, operated or managed by Caesars Entertainment Corporation or its affiliates. Our customers are encouraged to treat gambling the same way they treat other forms of recreation: to budget the time and amount of money they want to spend and to consider their chosen recreation as a pleasant pastime. We are proud that we entertain millions of customers each year. Our customers overwhelmingly tell us that they are entertained by engaging in gambling with us whether they win or lose or even just enjoying our non-gambling entertainment options on any particular occasion.

Promoting responsible gambling is part of our culture at Caesars. Our long-standing position has been that if a customer gambles with us for any reason other than the fun of it, that customer is playing for the wrong reason. Many observers have lauded our company’s industry-leading programs and practices in combating problem gambling. The advertising and marketing of our activities must be sensitive to these issues.

Caesars also provides a wide array of non-gambling entertainment options to its customers (such as dining, spas, shows, concerts and other events that do not include wagering) at our casino properties, non-gambling resort properties, stand-alone non-gambling amenities such as golf courses, and online or through mobile or internet-based play-for-fun and social game applications. Social games are games that may be played for free with a fun and entertaining focus to unlock new content within the game. They may or may not have themes related to traditional casino games. Play-for-fun-games are games simulating gaming activities without wagering, but they have an educational focus and customers may receive marketing materials related to gambling.

All of our advertising, for all of our products and services, must be truthful and consistent with generally accepted standards of good taste.

In order to codify our commitment to the principals of responsible gambling and responsible marketing more generally, Caesars has adopted this marketing and advertising code (the “Code”).

Marketing activity not specifically addressed in the Code will be evaluated in a manner that is consistent with the spirit of the Code.

Scope

  1. The Code applies to the marketing and advertising activities of Caesars Entertainment Corporation and its subsidiaries and affiliates (“Caesars”) that promote Caesars services or any of its brands, including, but not limited to, Caesars, Horseshoe, Harrah’s, World Series of Poker and Caesars Rewards. Caesars will also require any third party that uses a Caesars-licensed brand in connection with the operation of a business or service to comply with this Code. Caesars acknowledges, however, that some Code requirements may not be relevant or applicable to all brand licensees due to regulatory, cultural, or other reasons. In such instances, other documented standards will apply.
  2. For advertising to be considered “gambling advertising,” the advertising must directly market or promote gambling or gambling-related services, amenities or options. Advertising is not considered “gambling advertising” solely by virtue of the inclusion of a gaming or property brand or logo in a given advertisement or marketing material. For example, the use of the “Caesars Entertainment” or “Caesars” logo, or the “Caesars” brand name, in an advertisement does not in and of itself transform the advertisement into “gambling advertising.”
  3. The Code applies to every media or channel for marketing and/or advertising, including, but not limited to, direct mail, email or SMS messaging, outdoor, on property, radio, television, film, mobile devices, print, social media, and the Internet.
  4. The Code does not apply to content designed specifically to address the issues of underage or problem gambling. The Code also does not apply to the Caesars Foundation, Code Green, HERO, or Caesars Entertainment communications (absent the use of any logos of Caesars gaming brands including but not limited to its casino property logos). Finally, the Code does not apply to properties in jurisdictions which prohibit by law the offering or promoting of gambling activity, including Caesars Palace Bluewaters Dubai, Caesars Resort Bluewaters Dubai, and any properties which may open in such jurisdictions; for such properties, a jurisdiction-specific marketing and advertising code will apply.
  5. The Code applies to the advertising and marketing of (i) non-gambling amenities, (ii) non-gambling entertainment options and services, and (iii) non-gambling resort properties.
  6. The Code’s requirement for placement of a toll-free helpline number (in Section 14 below) applies to all gambling brand profiles on social media. Note: Individual, character-limited social media posts and messages are exempt from this requirement but, at a minimum, the main social media account page should include a reference to a toll-free helpline number.
  7. Caesars complies with all applicable local, state and federal laws and regulations (“Laws”) regarding marketing and advertising. These Laws may include limitations, restrictions, or other provisions that are different from those identified in the Code. In such cases, the more stringent of the Laws and/or the Code would apply.

Content

  1. Advertising and marketing materials shall portray all of Caesars’ activities and services, as well as customers experiencing such activities and services, in a responsible manner. Advertising and marketing materials for gambling activities are designed and intended for those of legal age to gamble in the relevant jurisdiction.
  2. Advertising and marketing materials are consistent with contemporary local standards of decorum and decency. Caesars is committed to diversity and inclusion. Advertising and marketing materials do not use images or language that is degrading to any group of people, including but not limited to individuals of any age, faith or religion, physical or mental ability, race, ethnicity, color, creed, national origin, gender, sexual orientation or gender identity or expression.
  3. Advertising and marketing materials shall not depict, encourage, or condone excessive, irresponsible, or illegal activity. Furthermore, they shall not:

a. State or imply that any of our activities or services is an acceptable means of satisfying work or family commitments, or an alternative to work or family commitments;

b. State or imply that any of our activities or services is necessary for financial, physical, emotional or social success;

c. State or imply that any of our activities or services solves personal problems;

d. Portray individuals who are intoxicated, who are compelled to gamble, who have lost control of their faculties, or who have become separated from reality; or

e. Suggest in any way that excessive, irresponsible or illegal use of our services or activities is amusing or acceptable behavior.

4.  We advertise and market gambling activities and/or play-for-fun services directly via telephone, mobile device, email or postal mail only to adults who are reasonably believed to be of legal age to gamble in the relevant jurisdiction. Our advertisements for our non-gambling resort properties, non-gambling and social games services and amenities made directly via telephone, mobile device, email or postal mail are intended only for adults, age 18 or over, with the exception of venues or events that require an older legal age to engage in the activity being advertised. Our marketing and advertising materials do not:

a. Show gambling being experienced by anyone under the legal age to gamble;

b. Use actors in advertising relating to gambling who are below 25 years of age or who reasonably appear to be below the legal age to gamble in their jurisdiction. This restriction shall not apply in real live footage, such as poker events or in the use of “celebrity” poker players, in which case all individuals shown must be of the legal age to gamble in their jurisdiction.

c. Use any symbol, language, gesture, cartoon, music, animated character, entertainment figure, or child’s toy in our gambling advertising or marketing material that has primary appeal to persons below the legal age to gamble in their jurisdiction. Material has a “primary appeal” to persons below the legal age to gamble in a casino if it has special attractiveness to such persons above and beyond the general attractiveness it has for persons above the legal age to gamble in their jurisdiction.

d. Show or imply that any of our activities or services is a “rite of passage” or otherwise necessary for the attainment of adulthood.

5. Advertising and marketing materials shall depict our resorts, casinos, and other businesses as respectable and well-kept establishments.

6. We do not market gambling materials or content to social games customers unless we have verified that they are of the legal age to gamble in the relevant jurisdiction.

7. All print gambling advertising includes a message offering a toll-free helpline for individuals who might have a gambling problem. The requirements for the message are subject to the rules or regulations of the relevant jurisdiction.

8. We sponsor public awareness, education, and other campaigns regarding problem and underage gambling.

Placement

1. We do not promote gambling at any event where the majority of the audience is reasonably expected to be below the legal age to gamble in that jurisdiction and we are sensitive to audience demographics for advertising or promotions involving alcohol or other age restricted products and services. Signage with the venue’s or the venue location’s name, logo, etc., is not considered a violation of this provision. Reasonable measures will be taken to ensure that those under the legal age to gamble in the relevant jurisdiction may not loiter on the casino gambling floor if attending an event or convention on a Caesars property, whether Caesars is a sponsor of the event itself or simply providing or sponsoring a venue. Notwithstanding the prohibitions in this provision, we may advertise and/or market at or near facilities that are used primarily for adult-oriented events, but which occasionally may be used for an event where most attendees are under the legal age to gamble in a casino, e.g., an arena or stadium.

2. No Caesars’ gaming brand, logo, trademark, or service mark is to be used or licensed for use on clothing, toys, game equipment or other materials that are intended primarily for persons below the legal age to gamble in the relevant jurisdiction. Materials that are intended primarily for persons below the legal age to gamble in the relevant jurisdiction, regardless of the presence of any product name, logo, trademark, or service mark, are not used as promotional materials or given away at events, except in response to an approved charitable request. Material is intended to be distributed primarily to persons below the legal age to gamble in a casino if it has special attractiveness to such persons above and beyond the general attractiveness it has for persons above the legal age to gamble in the relevant jurisdiction.

3. Advertising and marketing materials for gambling or play for fun activity are not placed in magazines, newspapers, television programs, radio programs, social media or other media where more than 30 percent of the audience is reasonably expected to be below 21 and/or the legal age to gamble in a casino in the relevant jurisdiction. Advertising and marketing materials for non-gambling amenities, including social games, are not placed in magazines, newspapers, television programs, radio programs, social media or other media where the majority of the audience is reasonably expected to be under the age of 18.

4. We do not advertise our products or brands in undergraduate college or university newspapers, with the exception of advertising for special events or venues that allow attendance only for those 18 years and above. Advertisements elsewhere in undergraduate college or university media are in conformity with policies promulgated by appropriate college or university officials, or with the prior approval of appropriate college or university officials.

5. We do not advertise our products, services or brands on the comic pages of newspapers or magazines.

6. New advertising of our gambling products, services or brands is not placed on any outdoor stationary location within 500 feet of an established place of worship or an elementary school or secondary school. If existing advertising is within 500 feet of said locations, contracts for its placement will not be renewed. For our websites that contain or advertise gambling or play for fun activities, we will:

a. Post that the website is intended for individuals who are 21 and/or of legal age to gamble in a casino in the relevant jurisdiction;

b. Include messages discouraging underage and irresponsible gambling;and

c. Include information about our responsible gambling philosophy, practices, and programs.

d. For our websites that offer online gambling, Caesars will require additional restrictions, such as age verification as required by any regulations in the relevant jurisdiction.

Compliance and Dissemination

1. A copy of this Code is available at every property to which it applies and on our internal website for employees and is available to any outside party who might request it.

2. A Code Review Board (“Board”) composed of Caesars executives communicate at least annually and evaluates Code compliance. An annual written report outlining the extent of Code compliance and, if necessary, describing means to ensure greater Code compliance, is prepared for the Board, in order to ensure that advertisements are placed in compliance with the Code.

3. The Board also communicates when necessary to consider issues, complaints or suggestions about Caesars marketing or advertising materials lodged by any interested party. If clear, objective evidence demonstrates to the Board that any advertising or marketing material is in violation of the Code, the material in question will be withdrawn as soon as reasonably possible. If appropriate, complaining parties shall be notified of the resolution of their complaints.

Effective Date

The provisions of this Code apply to any marketing or advertising activity undertaken on or after June 1, 2019.

For more information on the Caesars Entertainment Marketing and Advertising Code, please reach out to the Code Review Board at the following email address: CRB@caesars.com. Set forth below is contact information for specific questions regarding the Caesars Entertainment Marketing and Advertising Code, the Caesars Entertainment Code of Commitment and the Caesars Entertainment Responsible Gaming Program:

Marketing & Advertising Code and Code of Commitment (General Questions)

Lora Picini

Vice President of Equity, Strategic Policy & Regulatory Affairs

Caesars Entertainment Corporation

One Caesars Palace Drive

Las Vegas, NV 89109

Marketing & Advertising (Specific Scenarios/Questions for Review)

Dean Hestermann

Director, Issues Management and Strategic Communications

Caesars Entertainment Corporation

One Caesars Palace Drive

Las Vegas, NV 89109

Responsible Gaming Program Questions

Carolene Layugan

Director of Responsible Business & External Equity Engagement 

Caesars Entertainment Corporation

One Caesars Palace Drive

Las Vegas, NV 89109