National Human Tracking Awareness Day 2025: Multifaceted Human Trafficking Prevention Program Addresses Sands’ Zero-Tolerance Policy for Human Rights Violations

Under the People pillar of Sands’ corporate responsibility program is a core commitment to protecting the fundamental human rights of Team Members, guests, suppliers and business partners – underscored by a zero-tolerance policy for human rights violations. An essential component of this commitment is the company’s work to prevent human trafficking at its integrated resorts and in all facets of its business operations around the world.

“Human trafficking is a serious global human rights issue,” Puck Tsai, associate general counsel, global investigations and risk management, said. “We are deeply committed to preventing any form of human trafficking from taking place at our properties or within our supply chain.”

According to the U.S. Department of State, an estimated 27.6 million people are victims of human trafficking worldwide at any given time. Human traffickers prey on people of all ages, backgrounds and nationalities by exploiting them for profit.

“As the world has become more interconnected, more opportunities exist for wrongdoers to victimize disadvantaged groups,” Tsai said. “We take our responsibility to prevent these actions very seriously.”

To that end, Sands has established a multifaceted approach to address human trafficking globally.

Global Policies

The guiding principles for Sands’ human trafficking prevention program are outlined in a set of policies that define the company’s commitment to eliminating trafficking in any form. These guidelines include the Global Human Trafficking Prevention Policy, Code of Conduct and Business Ethics, Supplier Code of Conduct, Modern Slavery Statement and other human resources policies that are critical components of the company’s governance structure.

Collaboration

Using these policies and standards, the compliance, security, surveillance and hotel operations teams work closely to implement measures that prevent, detect and guide the company’s response to potential human trafficking red flags and incidents. Sands collaborates closely with law enforcement and regulatory agencies in all jurisdictions, as well as organizations that aid disadvantaged groups who may be at a higher risk of being victimized.

Training and Awareness

Sands requires all Team Members to complete human trafficking prevention training during onboarding and annually thereafter. Frontline Team Members receive additional, targeted training to detect and address suspicious activities.

“Our frontline Team Members often are in the best position to spot potentially harmful activity,” Tsai explained. “We provide guidance on how to maintain awareness, recognize signs and indicators, as well as how to appropriately respond. Team Members from different disciplines and departments must work together to ensure we are protecting against human trafficking to the best of our ability. That’s why our comprehensive training program is the lynchpin of our prevention initiatives.”

In addition to training, Sands runs a number of communications campaigns via Team Member channels to promote awareness and provide ongoing education about human trafficking signs and response mechanisms.

Operational Action

Led by former law enforcement officials, the company’s security teams work closely with its surveillance teams to employ both public and covert strategies to minimize the potential for human trafficking at its resorts. All properties provide well-publicized reporting avenues for Team Members and guests to report suspected incidents, including alerting security or management personnel, contacting Sands through channels established on corporate and property websites, or using the company’s 24-hour confidential ethics hotline. Prominent signage throughout the properties ensures Team Members and guests have access to hotline information, which is available in multiple languages and via telephone, website or QR code.

Supplier Engagement

Sands requires suppliers to provide fair and safe conditions for all workers, treat their employees with dignity and respect, and take proactive steps to minimize the potential for any form of forced, involuntary, coerced or child labor in their businesses and supply chains.

As part of the supplier onboarding process, global procurement and compliance teams conduct extensive due diligence procedures that include an assessment of potential human rights violations. Additional requirements include mandatory adherence to Sands’ Supplier Code of Conduct, annual supplier risk assessments, ongoing audits and evaluations, and corrective actions and remediation as necessary.

“The standards and processes we have for preventing human trafficking extend to all partners and throughout our supply chain, including companies involved in our development and construction projects,” Tsai said. “We work to prevent forced labor at every single phase of our business operations.”

Evaluation and Monitoring

In 2023, Sands undertook a comprehensive review of its global human trafficking prevention program. The assessment focused on relevant hotel, leisure and casino industry risks, such as forced labor, unethical recruiting practices, sex trafficking and supply chain misconduct. This extensive review concluded that the company’s program is effective and encompasses industry best practices.

As part of this review, Sands also prepared a Modern Slavery Statement that was published in line with the requirements of the U.K. Modern Slavery Act. The statement was approved by the company’s board of directors and can be found on Sands.com.

“The results of our review showed that we have a very good program in place to mitigate risks,” Tsai said. “We are an industry leader in this important space and continue to pay close attention to human rights in all aspects of our business and operations.”

Sands’ human trafficking prevention program is part of Sands Project Protect, an umbrella for a set of comprehensive global programs that provide safeguards and formalized actions to encourage responsible gaming, prevent financial crime and implement counter-trafficking measures.

To learn more about the company’s efforts to promote safety and ensure protections at its properties around the world, read the latest environmental, social and governance report: https://www.sands.com/resources/reports/