WHISTLE BLOWER POLICY

WHISTLE BLOWER POLICY

All employees of Dave & Buster’s are encouraged to report either orally or in writing to their immediate supervisor, or alternate line of authority as hereinafter described, all evidence of activity by a Dave & Buster’s department or employee that may constitute:

• Corporate fraud;
• Unethical business conduct;
• A violation of local, state, or federal law; or
• Substantial and specific danger to the employee’s or public’s health and safety.

Any Dave & Buster’s employee who in good faith reports such incidents as described above will be protected from threats of retaliation, discharge, or other types of discrimination including but not limited to compensation or terms and conditions of employment that are directly related to the disclosure of such reports.  In addition, no employee may be adversely affected because the employee refused to carry out a directive which, in fact, constitutes corporate fraud or is a violation of local, state, or federal law.

Any employee who wants to report alleged improper activity as described above should contact his or her immediate supervisor, or the supervisor’s manager.  In instances where the employee is not satisfied with the supervisor or manager’s response, or is uncomfortable for any reason addressing such concerns to his or her supervisor or the manager of such supervisor, the employee may contact the General Counsel.  If the employee is uncomfortable for any reason contacting the General Counsel, the employee may contact the Chair of the Audit Committee of the Board of Directors.  Alternatively, the employee may utilize an anonymous hotline and/or website established by Dave & Buster’s to collect such information.  The hotline may be reached, 24 hours a day, by dialing 1-888-400-4445.  The website is accessible by logging onto http://daveandbusters.silentwhistle.com.  The employee is encouraged to provide as much specific information as possible including names, dates, places, and events that took place, the employee’s perception of why the incident(s) may be a violation, and what action the employee recommends be taken.  Anonymous written or telephonic communications will be accepted.  Each employee who chooses to identify him or herself will receive a reply to his or her report within twenty (20) business days or as soon as practicable thereafter.

CONTACTS 

The General Counsel will maintain a log of all reports, tracking their receipt, investigation and resolution and shall prepare a periodic summary report for the Audit Committee.  Complaints determined by the General Counsel to be material in nature will be reported to the Chair of the Audit Committee immediately.