In accordance with our Political Contribution Policy, we encourage our employees to participate in political activities on their own time and at their own expense, and in a manner consistent with applicable law and our applicable policies. The Political Contribution Policy sets forth internal safeguards to prevent unlawful political contributions by the Company and its officers, employees and directors who are licensed or have applied for a gaming license in one or more of the jurisdictions in which the Company is licensed. Federal law and many state and local laws prohibit corporate contributions to political parties or candidates. Company assets, facilities and resources may not be used for political purposes except in accordance with law and after approval by the Board of Directors.

Trade and Industry Group Membership

We are a member of certain trade and industry associations, including the National Association of Real Estate Investment Trusts (Nareit) and the American Gaming Association (AGA). Our objective is to generally support each organization’s respective operations and priorities and the key sectors in which we operate, specifically REITs and the American gaming industry, including advocacy on behalf of members. In 2023, we paid a total of approximately $438,000 in membership dues to Nareit and the AGA, any portion of which utilized for lobbying and political activities was allocated by the respective organizations and not directed by VICI. Except for such portions of these membership dues (which are not directed by VICI), we have not expended corporate resources for political advocacy purposes as described below.

Political Participation

Since our formation, we have not made (i) any corporate contributions to political candidates, parties or committees, (ii) any payments to organizations organized under Section 527 of the U.S. Internal Revenue Code (26 U.S.C. § 527), (iii) any independent political expenditures in direct support of or opposition to a political campaign, (iv) any payments to influence the outcome of ballot measures, or (v) any payments to other tax-exempt organizations, such as 501(c)(4)s, that the recipient may to our knowledge use for political purposes. Accordingly, no information on specific recipients or amounts of such contributions, payments or expenditures is available.

Political Contribution Policy

Our Political Contribution Policy, in addition to our Code of Business Conduct, provides:

• that Company personnel are encouraged to participate in political activities on their own time and at their own expense, and in a manner consistent with applicable law and the Company’s applicable policies;
• ​that Company assets, facilities and resources may not be used for political purposes except in accordance with law and after approval by the Board of Directors;
• ​for the implementation of internal safeguards to prevent unlawful political contributions by the Company and our officers, employees and directors who are licensed or have applied for a gaming license in one or more of the jurisdictions in which we are licensed, due to the highly regulated nature of the gaming industry in which we operate; and
• ​for the strict prohibition on making illegal payments to government officials of any country, including under the U.S. Foreign Corrupt Practices Act, which prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business, and similar federal, state and local rules, as well as those of foreign governments.

Our Board of Directors periodically reviews the Political Contribution Policy.

Last updated: September 9, 2024