CDC’s “Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19)” document recommends that employers plan to respond in a flexible way to varying levels of transmission in the community and be prepared to refine their plans as needed. Activities noted include efforts to reduce transmission among Team Members, maintain healthy business operations, and maintain a healthy work environment.

When Wind Creek Hospitality voluntarily closed all of its facilities at the outset of the COVID-19 pandemic, we implemented important steps to assist our Team Members. Namely, we continued to provide our full-time Team Members with their wages and benefits even when our facilities were closed. Wind Creek Hospitality also took steps to protect Team Members by providing telework arrangements and/or other workplace accommodations. As we continue to resume our operations, we will continue to take steps consistent with guidance from the CDC and other public health sources to protect all of our Team Members.

Upon resumption of operations, Wind Creek Hospitality Team Members who appear to have symptoms (e.g., fever, cough, or shortness of breath) upon arrival at work, or who exhibit symptoms during the day, will be sent home. If a Team Member is confirmed to have COVID-19 infection, we will strive to inform fellow Team Members of their possible exposure to COVID-19 in a manner consistent with applicable confidentiality and privacy requirements.

Wind Creek Hospitality will work to educate Team Members about COVID-19 based on CDC Public Health Recommendations for Community-Related Exposure.

Wind Creek Hospitality has taken significant efforts to maintain, implement, and enforce policies and procedures in a flexible manner. In this difficult time, we have implemented supportive practices to provide Team Members with the ability to care for themselves, family members and dependents. As Wind Creek Hospitality prepares to reopen, it will continue to take a supportive and flexible approach to its Team Members.

Wind Creek Hospitality’s Employee Expectations Guide provides flexibility to managers to provide Team Members the ability to care for a sick family member or children due to school and childcare closures. Administrative Leave can be granted on a case-by-case basis. Wind Creek Hospitality has an employee assistance program (EAP) and will continue to make these resources available to Team Members who may need additional social, behavioral and other services, for example, to cope with the death of a loved one.

Wind Creek Hospitality seeks to inspire and empower its Team Members. We believe that each Team Member will do what they need to do to be at work and provide an escape to Guests while they are on property. Should we experience a spike in absenteeism due to increases in sick Team Members, Team Members who must stay home to care for sick family members, and those who must stay home to watch their children if dismissed from childcare programs and K-12 schools, we have contingency plans in place. Should absenteeism reach a level that we can’t work around, we think such an event would coincide with a public health situation that would require our property to close.

In addition to Social Distancing and face covering protocols, and the disinfection and sanitization practices discussed above, Wind Creek Hospitality will increase the ventilation rates in our properties as well as the ratio of fresh air to recirculated air within our HVAC systems. For Team Members and Guests, we will provide numerous hand-sanitization dispensers throughout the properties and promote the CDC’s personal hygiene recommendations.

In our Team Member workspaces, we will routinely clean and disinfect all frequently touched surfaces such as workstations, keyboards, telephones, handrails and doorknobs. After persons suspected/confirmed to have COVID-19 have been in the facility, we will also perform enhanced cleaning and disinfection of their workspaces.

For our Team Members who must travel, we will advise them before their travels to take additional preparations consistent with CDC guidance.

CDC’s “Interim Guidance for Businesses and Employers to Plan and Respond to Coronavirus Disease 2019 (COVID-19)” and OSHA’s “Guidance on Preparing Workplaces for COVID-19” address multiple issues that Wind Creek Hospitality believes can help mitigate the exposure and spread of COVID-19 among our Guests when they visit our properties. In addition to these guidelines, Wind Creek Hospitality will also abide by applicable public health directives.

Collectively, these guidelines indicate that Social Distancing is an important mitigation strategy that we will continue to maintain at our properties—whether it be Team Member work areas, or Guest-accessible areas. Social Distancing guidance suggests that 6 feet of space should be maintained between people. Wind Creek Hospitality will develop and enforce property occupancy levels and other measures that provide a minimum of 6 feet of space between Guests at our properties. Occupancy levels will be significantly less than the posted Fire Marshal Occupancy levels, and in many (if not all) cases, they may be significantly less than state or local law might require.

• These reduced capacity limits will allow WCH to reopen in a manner to allow Social Distancing to occur between games and throughout the property.

Currently, the CDC states that some individuals may be considered to be at a higher risk in the event they contract or are exposed to COVID-19. Wind Creek Hospitality will implement efforts to educate the public as to the CDC’s guidance associated with increased risk for certain individuals.

• WCH will post public notice and include in media campaigns that older adults and persons with severe pre-existing health conditions are at increased risk if they contract COVID-19 and they should make any decision to visit a Wind Creek property with this risk in mind.
• WCH will require Team Members and Guests to wear face coverings while present in public and back-of-house spaces at a Wind Creek property as a step all can take to mitigate exposure of at-risk patrons and Team Members to COVID-19.
• Smoking will not be allowed inside the property. Designated smoking areas (with Social Distancing expected) will be provided at each property.

CDC notes that the level of transmission in our local communities and the level of transmission in the areas from which our visitors will travel can impact decisions regarding opening and closing.

• WCH will monitor COVID-19 caseloads and other criteria of each county that is home to our property, and the surrounding counties that are home to our Guests.
• WCH may deny entrance to our properties to Guests who arrive from a county that may represent minimal, moderate or substantial levels of COVID-19 community transmission.
• WCH may consult with local, state and other public health officials for insight and advice regarding its operations.

Wind Creek Hospitality’s decision as to when to reopen its facilities will be based upon input and guidance from our medical and public health advisors, and considerations outlined by the CDC and other public health sources.

We may choose to open a property at a date later than otherwise allowed by a state or local order, if we believe that such action is in the best interest of the health and safety of our Team Members and Guests.

Upon establishment of a date that one (or several) of our properties can reopen, the reopening of a Wind Creek property will proceed under one of two modes, depending on community and surrounding area conditions related to the transmission of COVID-19. In either mode, Guest capacity at a property will be limited. The modes are:

1. SOFT OPEN: Guest capacity at a Wind Creek property will be limited to 249 people or less per session. Per CDC guidance, this level is less than Mass Gathering levels. Access to the property may be by invitation and or with a reservation system in place.

2. REDUCED CAPACITY OPEN: Guest capacity will be limited in accordance with legal requirements, public health guidance and our own judgment to facilitate Social Distancing and to accommodate other mitigation efforts. Access to the property may be by invitation and or with a reservation system in place. Initial Capacity levels (in number of Guests) will be set based on the number of gaming positions that can be provided while meeting the CDC Social Distancing guidelines. Over time, based upon conditions in our property’s community and surrounding areas, input and guidance from our medical and public health advisors, and other public health sources, we may increase the capacity from the Initial Capacity levels to the property’s Fire Marshall Occupancy levels.

   The following table provides capacity levels for each mode of opening, reference to Fire Marshall Occupancy at a 35% rate, and normal Fire Marshall Occupancy for the properties.

   

3. In both SOFT OPEN and REDUCED CAPACITY OPEN, Social Distancing concepts and other mitigation protocols will be utilized. Mitigation protocols will include:
   • Implementation of Social Distancing measures in front-of-house and back-of-house areas.
   • Regular closures of the gaming floor by section throughout the day and an entire floor deep cleaning at/around 3 A.M.
   • Focus on hygiene and sanitization practices with supplies readily available.
   • Limit maximum group size to four people (parties of more than four will be asked to split into socially distanced groups of four or less).
   • Maximize opportunity for Team Members to telework.
   • Limit in-person meetings, meeting for lunch in a break room, etc.
   • Limit large work-related gatherings (e.g., Team Member meetings, after-work functions).
   • Limit non-essential work travel.
   • Implement health checks (e.g., temperature and other appropriate screenings) of Team Members entering buildings.
   • Prior to the closure of Wind Creek Hospitality’s properties, WCH provided all Team Members with additional paid time off (PTO) (up to 10 working days), available to use as-needed due to COVID-19 considerations (COVID-19 PTO).
4. Property Reclosing: In the event that a controlling public authority indicates that a Wind Creek Hospitality property must be closed, we will close that property. Additionally, if we believe it is in the best interest of our Team Members and Guests to close, we will do so voluntarily—regardless of whether we are asked to do so (as we did with our first voluntary closure).
5. Return to Normal Operations: We do not know when we will be able to fully open our properties and operate in the manner that we did prior to the COVID-19 pandemic. When it is prudent to do so, we will increase occupancy at our properties (taking into account the regional situation that applies to each) and we will continuously seek ways to enhance the sense of escape that we want every Guest to enjoy when they visit one of our properties.

Through media announcements, social media, our websites, digital properties and Guest contact, we will let the public know the operating status of our properties.

As discussed above, current guidance from the CDC and state and local health departments suggests that Social Distancing (spacing of 6 feet between individuals) should be maintained to mitigate the spread of COVID-19. While mass-gathering restrictions and/or Social Distancing guidance remains in place, Wind Creek Hospitality will establish occupancy in its gaming and other publicly accessible areas in accordance with CDC and state and local guidelines and orders.

We will ask our Guests to maintain 6 feet of Social Distancing at all times. For Guests who visit our properties alone, we will encourage them to maintain a 6-foot distance from other people. If a couple or a group of not more than four visits our properties, we will encourage them to maintain at least a 6-foot separation from other people and groups. If a group of more than four people arrive together then they will be asked to split into groups of four or less to maintain Social Distancing.

If after repeated requests by our staff to maintain Social Distancing spacing, someone or a group continues to infringe upon the Social Distancing space of another person or group, the offending person or group will be asked to leave the property. Wind Creek Hospitality reserves the right to enforce its Social Distancing guidelines in its sole discretion.

Hotel Occupancy
While Social Distancing guidance remains in place, we will operate our hotels at an occupancy rate in accordance with applicable guidelines and orders. When Guests depart a room, that room will be left undisturbed for a minimum period of 2 hours before it is sprayed with Shock-Wave, then the room is cleaned and returned to service (made available to the next Guest).

Restaurants
While Social Distancing guidance remains in place, we will reconfigure our restaurant seating to provide Social Distancing space between diners. Additionally, all self-service dining options will be replaced with wait-staff service only. In all instances, we will operate our restaurants or food service and dining offerings pursuant to applicable guidelines or orders.

Other Amenities
Other amenities at our properties may or may not be available to the public until a return to normal operations. Other amenities that we do open to the public will be offered under the same criteria that apply to our other public spaces, and with other appropriate steps as may apply to the unique offering of each amenity.