Intellectual Property

Patents, trademarks, copyrights, and trade secrets are all considered to be intellectual property. Every person at CIRI has an obligation to protect these assets and to respect the intellectual property rights of others. As part of this obligation, people at CIRI may not make unauthorized use or copies of copyrighted documents or computer software. CIRI will take necessary measures to protect CIRI's intellectual property, including CIRI's logo, work product, and other work, whether by someone at CIRI or independent contractors. Any individual who engages in transactions that involve CIRI's logo and other intellectual property should consult with the Legal Department.

International Business

While CIRI is a domestic corporation, the company or its subsidiaries may, from time to time, do business outside of the United States. Under such circumstances, we must be aware of the unique laws, rules, regulations, cultures, and customs that may guide our business activities overseas. This includes following the laws of foreign countries as well as having a comprehensive understanding of and being in full compliance with the United States Foreign Corrupt Practices Act ("FCPA"), which prohibits payments (either directly, indirectly, or through a third party) to foreign government officials, parties, or candidates for the purposes of influencing favorable government action or obtaining/retaining business. Any individual who may conduct business outside of the United States on behalf of CIRI should consult with the Legal Department for guidance on the proper ethical and legal conduct in such circumstances.

Political Participation

In order to avoid impropriety and the appearance of impropriety in corporate dealings with political officials, strict laws at the local, state, and federal levels have been established to regulate contributions to, and lobbying of, public officials. These laws include certain restrictions on corporate and individual contributions to political campaigns, gifts to public officials, and certain lobbying activities. These laws are complex and vary from state to state and political office to political office. Any person at CIRI who engages in any activity involving the use of corporate resources or the company name in connection with any politically related activity, or who engages in direct contact with elected or appointed officials on behalf of the company should consult with the Legal Department to ensure that CIRI is complying at all times with the applicable legal and ethical standards of conduct.

Regulatory Investigations, Inspections, and Requests for Information

From time to time, CIRI may be asked for information from government agencies, including regular reporting in connection with our gaming activities, or may be the subject of governmental audits, inspections, or investigations. All such inquiries should be referred to the Legal Department promptly and will be handled courteously, cooperatively, and professionally. CIRI will never lie or make misleading statements, attempt to cause another employee to fail to provide accurate information, and/or obstruct, mislead, or unnecessarily delay the communication of information or records related to a possible violation of the law. During such investigation, the CIRI Legal Department will work to assure our responses are timely, complete, and factual.

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