Empire Racing Unveils Corporate Integrity Program

(Edited press release)
Empire Racing, the Saratoga-based finalist for New York state's racing franchise, unveiled a corporate integrity program Dec. 5 that includes creation of an independent inspector general and a board of directors integrity task force headed by two independent directors with no financial interests in the company.

Empire's plan uses a system of checks and balances to improve corporate governance and make the operations of the New York racing franchise more transparent to the public. The plan will form a major part of the proposal that Empire Racing will present to the state legislature and the executive.

"To return to its rightful place as a world leader in thoroughbred racing, the New York racing franchise must be treated as a public trust where integrity, transparency and professionalism are vital attributes," said Empire Racing chairman Jeffrey Tucker.

Empire's corporate integrity program focuses on corporate governance, transparency, and professionalism, and was developed by Denise O'Donnell, the former United States attorney for the Western New York district.

The following is a summary of Empire's integrity plan:

Strong Corporate Governance:

--Corporate Inspector General: Empire Racing's management team will include an independent, senior-level executive corporate inspector general position which will ensure a strong compliance culture within the company.

--Permanent Integrity Task Force of the Board of Directors: Empire Racing's board of directors will maintain a permanent integrity task force that will be led by two independent directors that have no financial interest in racing.

--Site-based Compliance Officers: Each racetrack facility will have its own compliance officer to ensure that all activities are conducted in compliance with the Code of Ethics and all applicable laws, rules, and regulations.

--Integrity Hotline: A new toll-free integrity hotline will be created and publicized to encourage employees and the public to report information regarding possible offenses. The corporate inspector general will be charged with initiating a timely investigation and disposition of the investigation and submitting a quarterly written report to the board's integrity task force.

--Regular Professional Training of Investigators and Security Officers: In addition to having properly licensed and regularly trained security officers and investigators, the new director of security will work proactively with the inspector general to establish and promote a culture of corporate integrity throughout the racing franchise.

--Employee Integrity Assessments: All employees will be required to undergo yearly assessments to ensure that all legal and ethical requirements are being upheld. Employees will also be required to complete a comprehensive background check and verify citizenship status prior to employment.

--Employee Recognition: Corporate integrity incentive awards will be presented annually to employees who have exemplified the highest level of ethics and integrity.

Transparent Organization:

--Annual Report: Empire will issue a regular year-end report to the public within 30 days of the close of each business year. The report will include audited financial statements and highlight major business and operational developments.

--Lobbying Compliance: Pursuant to the state's lobbying commission ruling that the franchise process falls under lobbying law provisions, all Empire Racing employees who have or could reasonably expect to interact with public officials have registered as lobbyists with the state. Empire files regular bimonthly reports with the commission.

--Full Disclosure: Empire Racing has publicly identified all parties in interest and all persons who have a financial interest in the venture and/or who have assisted Empire in its franchise efforts. Empire has done this by complying with the Ad Hoc committee's "bidder identification" process. Empire will continue to identify all parties in interest throughout the legislative procurement period and beyond.

--Public Discussion: Empire Racing has openly discussed its plan to revitalize New York racing and has scheduled a series of public forums to solicit further input from New York racing fans and taxpayers. The first public forum is scheduled for Jan. 10, 2007, in Saratoga Springs.