Disclosure Policy

CHURCHILL DOWNS INCORPORATED DISCLOSURE POLICY

Churchill Downs Incorporated is committed to providing timely, orderly, consistent and credible information, consistent with legal and regulatory requirements, to enable orderly trading in our publicly held securities.

This disclosure policy affirms the Company's existing policy. Its purpose is to develop and maintain realistic investor expectations by making all required disclosures on a broadly disseminated basis, without being unduly optimistic or pessimistic on prospects for future Company performance, in a manner that provides to all investors the opportunity for equal access to such information consistent with the Securities Exchange Commission's (SEC) Regulation FD and other legal and regulatory requirements. It is also the Company's policy that when the Company or "a person acting on its behalf," as defined by Regulation FD, makes disclosure of non-public, material information, such disclosure shall not be made selectively but shall be made in a manner that provides broad, non-exclusionary distribution of the information to the public.

Disclosure Policy Committee
Review of Disclosure Communications
Responsibilities of the Company's Authorized Spokesperson(s)
Policy Regarding Employees Who Are Not Authorized Spokespersons
Policy on Non-Intentional Disclosure
Policy on Reviewing Analysts' Reports
Policy on Distributing Analysts' Reports
Policy on Commenting on Analysts' Earnings Estimates
Policy on Assisting New Analysts
Policy on Responding to Rumors
Policy on Responding to Market Activity
Policy on Material Developments
Policy on Memoranda of Understanding
Policy on Forward-Looking Statements
Policy on Forward-Looking Statements Related to Earnings
Policy on Drafting and Disseminating News Releases
Policy on Conference Calls
Policy on Disclosing Presentation Materials
Summary

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