Integrity Policy
Please read this TGL Integrity Policy (the “Policy”) carefully and, if applicable, distribute it within your organization. By accepting this Policy, you agree (on behalf of yourself and, if applicable, your organization) to be bound by this Policy in its entirety, including its release of liability and waiver of judicial review. Ignorance of the terms of this Policy will not be considered a mitigating factor in the event of a violation of this Policy. TGL may amend this Policy at any time. Any such amendment shall bind all then-current Covered Persons upon their notification of the amendment.
1. INTRODUCTION
(a) Purpose
TGL League LLC (“TGL”) has developed this Policy for the primary purpose of preventing betting-related corruption in TGL competitions. That said, the general mission of this Policy is as follows:
To maintain integrity and to prevent and mitigate betting-related corruption in TGL and other golf- and golf-related competitions – ensuring competitions always reflect, and appear to reflect, the best efforts of the players, while protecting the welfare of the players and others involved with TGL and in those competitions – through clear policies and regulations, ongoing education and training, and effective and consistent monitoring and enforcement functions.
(b) Scope
This Policy applies to Betting related to TGL and other professional golf, amateur golf, collegiate golf or other golf- or golf-related competitions or events, whether or not affiliated with TGL, anywhere in the world (“Golf Competitions”).
As used herein, “Betting” means (A) placing any money or other thing of value on the occurrence of an uncertain outcome with the possibility of return or (B) participating in any fantasy or other game that is impacted by real-world information and events and that awards a prize of value, including any free-to-play, paid or daily fantasy game, unless expressly exempted by TGL.
(c) Covered Persons
This Policy applies to the following persons (“Covered Persons”):
(i) Contractors and Partners. TGL and TGL team consultants, contractors, vendors and partners whose role in supporting TGL and/or TGL team(s) provides them access to, or knowledge of, Inside Information. “Inside Information” means non-public or not-yet-public information related to Golf Competitions, players, performance or news, or other information relevant to Betting (e.g., the health of a player, the conditions of a course, etc.).
(ii) Teams. TGL team owners, employees and part-time employees.
(iii) Directors. Each non-player director of TGL’s (or any of its affiliates’) board.
(iv) Employees. Each employee and part-time employee of TGL or any of its affiliates.
(v) Credentialed Personnel. Each person who receives a credential to access a TGL event (e.g., media members).
(d) Former Covered Persons
TGL retains the right under this Policy to investigate, bring actions against and sanction any person who is no longer a Covered Person but committed a violation of this Policy while a Covered Person; and such person will be deemed to be a “Covered Person” under this Policy for such purposes.
(e) Integrity Officer
This Policy will be overseen by the “TGL Integrity Officer,” who will be designated by TGL in its sole and absolute discretion. TGL shall have the right to terminate the TGL Integrity Officer at any time for any reason.
2. PROHIBITED CONDUCT
The following conduct is prohibited:
(i) Betting on Golf Competitions. Any Covered Person, directly or indirectly, Betting on any Golf Competition.
(ii) Failing to Give Best Efforts. Any Covered Person, directly or indirectly, encouraging or inducing any player to fail to give best efforts in any Golf Competition.
(iii) Contriving an Outcome. Any Covered Person, directly or indirectly, contriving or attempting to contrive the outcome or any other aspect of any Golf Competition.
(iv) Facilitating Unauthorized Access. Any Covered Person facilitating a third party’s access to a Golf Competition for the purpose of conducting unauthorized activities in relation to Betting.
(v) Other Betting-Related Activities. Any Covered Person engaging in Betting-related activities or associating with any Betting-related person(s) in a manner that will or might (in TGL’s sole discretion) reflect adversely on the integrity or the appearance of integrity in any Golf Competition.
(vi) Betting Advice. Any Covered Person providing or conveying advice, analysis, tips or insight to a third party for Betting privately or publicly (e.g., Betting picks for a TGL event), provided that this restriction will not apply to a Covered Person acting in the course of his or her professional duties as approved by TGL.
(vii) Providing Inside Information. Any Covered Person providing Inside Information to a third party that he or she knows (or should know) will be, or is likely to be, used for Betting on the outcome of any Golf Competition.
3. REPORTING OF VIOLATIONS
(a) Obligation to Report
Each Covered Person shall immediately report to TGL if: (i) he or she becomes aware of any activity that would reasonably be expected to constitute, or to lead to, a violation of this Policy by any Covered Person; and (ii) he or she is, or he or she becomes aware that any other person has been, approached by any person who offers any money or other thing of value to influence the outcome or any other aspect of a Golf Competition or to provide Inside Information for Betting. For clarity, the failure to report information under this Section will be deemed to be a violation of this Policy.
(b) Anonymous Reporting Lines
TGL will maintain an email address and telephone lines for the reporting of information, as follows:
Email: reports@suntrio.com
U.S. and Canada Calls (English-speaking): (833) 214-2442
U.S. and Canada Calls (Spanish-speaking): (800) 216-1288
Website: https://report.syntrio.com/tmrwsportsgroup
Further, Covered Persons may report such information directly to the TGL Integrity Officer at any time. If a reporting person desires to report information anonymously, TGL will seek to maintain the confidentiality of the identity of the reporting person (if known), unless otherwise required by applicable law or approved by the reporting person.
4. EDUCATION
Certain Covered Persons identified by TGL will be required to complete an online educational program regarding Betting-related corruption. Covered Persons are encouraged to contact the TGL Integrity Officer at any time if they wish to receive any additional educational assistance.
5. MONITORING
TGL will, with the assistance of a third-party service provider, monitor for irregularities in the global betting markets for TGL events. If TGL becomes aware of any irregular activity in the betting markets or of any other activity that suggests a violation of this Policy may have occurred, TGL will review the matter and determine whether an investigation is merited.
6. INVESTIGATIONS
(a) Investigation Unit
Each investigation of a potential violation under this Policy (“Investigation”) will be conducted by an Investigation Unit. “Investigation Unit” means one or more independent consultants, TGL personnel, or other persons designated by TGL. The Investigation Unit may, but is not required to, notify each relevant Covered Person that he or she is subject to an Investigation.
(b) Cooperation with Investigation
Each Covered Person subject to an Investigation shall cooperate fully with the Investigation. Each such Covered Person shall, without limitation: (i) timely provide (and hereby waives any right to withhold) information and records requested by the Investigation Unit for purposes of the Investigation, which may include telephone records, text messages, emails, financial records and storage devices; (ii) provide, as requested by the Investigation Unit, a true and complete written statement and/or oral interview setting forth facts and circumstances with respect to the Investigation; and (iii) not tamper with or destroy evidence that is or could be relevant to an Investigation, or otherwise deliberately hinder an Investigation in any way. Each Covered Person consents to the collection and use of information relating to him/her, including personal information, by TGL and/or the Investigation Unit for purposes of the Investigation and any Disciplinary Procedure. The failure of a Covered Person to comply with this Section 6(b) will be deemed to be a violation of this Policy.
(c) Coordination with Criminal Authorities
If any matter subject to an Investigation hereunder is also subject to a criminal investigation or any other similar proceeding, including any action brought by any regulatory authority, in any jurisdiction, TGL may coordinate with the relevant law enforcement and other authorities in TGL’s discretion. In connection therewith, TGL may disclose information relating to the Investigation hereunder to the relevant authorities. Further, TGL may use information obtained from the relevant authorities in the Investigation hereunder. TGL may continue to conduct, or suspend, the Investigation hereunder during a criminal investigation or similar proceeding in its discretion, subject to applicable law.
(d) Findings of Investigation
The Investigation Unit will report its findings from the Investigation to TGL for review and consideration.
7. DISCIPLINARY PROCEDURES
(a) Procedure
TGL has the right, in its sole and absolute discretion, to discipline and sanction Covered Persons for violations of the Policy. If TGL commences any disciplinary procedure, TGL will notify the relevant Covered Person in writing of the applicable possible violation of this Policy and the commencement of the disciplinary procedure. The Covered Person will cooperate fully with the disciplinary procedure. Through the disciplinary procedure, TGL will determine, in its sole and absolute discretion: (i) whether the Covered Person has violated this Policy and (ii) the sanctions to be imposed on the Covered Person for any violation(s). TGL will notify the Covered Person of the determination by written notice. The determination will be the full, final and complete disposition of the matter (unless TGL, in its sole and absolute discretion, grants the Covered Person an appeal) and will be final and binding on the Covered Person.
(b) Waivers
To the fullest extent permitted by applicable law, each Covered Person hereby (i) waives and agrees not to assert any right to judicial review or other appeal of TGL’s determination(s) under paragraphs 7(a), 8 and/or 9; (ii) agrees that TGL and its affiliates shall have no liability of any kind in connection with their enforcement of this Policy and releases TGL from any such liability; and (iii) hereby waives and agrees not to bring any claims of any kind against TGL in connection with the enforcement of this Policy.
8. SANCTIONS
(a) Sanctions for Covered Persons
Sanctions for a Covered Person due to violation(s) of this Policy may include (but are not limited to):
(i) A warning;
(ii) A required education program;
(iii) Monetary fines and removal from TGL events and competitions;
(iv) The temporary and/or permanent denial of access and/or credentials to TGL events;
(v) Contract rescission;
(vi) Removal from the TGL (and/or, as applicable, its affiliate’s) board;
(vii) For employees, disciplinary action up to and including termination of employment.
(b) Fulfillment of Sanctions
If a Covered Person fails to fulfill any sanctions, TGL may, in its sole discretion, deem such failure an additional violation of this Policy and impose additional sanctions hereunder.
9. PROVISIONAL SUSPENSIONS
TGL may impose a provisional suspension of a Covered Person at any time prior to a final determination under Section 7 above (including at any time prior to the conclusion of an appeal) (a “Provisional Suspension”) if TGL believes it is likely a violation of this Policy was committed or believes the integrity and/or reputation of TGL and/or the game of golf would be undermined absent a Provisional Suspension. A Provisional Suspension may consist of a suspension of the right to participate in TGL events, receive credentials or access to TGL events, volunteer for TGL events, serve on the TGL (or any affiliate’s) board or be employed by TGL. A Provisional Suspension will be effective upon the delivery of written notice thereof from TGL to the relevant Covered Person.
10. DISCLOSURES OF INFORMATION
TGL may publish and disclose information related to Investigations and other information relating to this Policy (and its enforcement) publicly or privately as deemed appropriate or necessary by TGL in its discretion. Without limitation, TGL may: (i) disclose such information to other governing bodies in golf; (ii) disclose such information to law enforcement and governmental, regulatory and judicial authorities; (iii) issue any public statement or correct any public record or account; and (iv) publish statistical information about this Policy (and its enforcement).