Sports Global Group Plc
Last reviewed: 1st of August 2026
Approved by the Board: 10th of August 2026
1. Policy Statement
Sports Global Group Plc ("SGG" or the "Group") is committed to conducting its business with integrity, transparency and the highest standards of ethical behaviour.
The Group operates a zero-tolerance approach to bribery and corruption.
SGG will not tolerate bribery, corruption, improper payments or other improper inducements by or involving any Director, employee, subsidiary, representative, agent, consultant, intermediary, supplier, contractor, business partner or other person acting for or on behalf of the Group.
The Board of Sports Global Group Plc is committed to ensuring that appropriate policies, procedures and controls are maintained to prevent bribery and corruption throughout the Group's activities.
2. Scope
This Policy applies to:
• Sports Global Group Plc;
• all subsidiaries and businesses controlled by SGG;
• Directors and officers;
• employees, whether permanent, temporary or fixed-term;
• consultants and contractors;
• agents and representatives;
• distributors and intermediaries;
• joint-venture participants where appropriate;
• suppliers and other business partners; and
• any person performing services for or on behalf of the Group.
Everyone covered by this Policy is expected to conduct business honestly and in accordance with applicable laws and this Policy.
3. The Bribery Act 2010
SGG conducts its business in accordance with the principles of the UK Bribery Act 2010 and other applicable anti-bribery and anti-corruption legislation.
The Bribery Act includes offences relating to:
• offering, promising or giving a bribe;
• requesting, agreeing to receive or accepting a bribe;
• bribery of a foreign public official; and
• failure by a commercial organisation to prevent bribery by persons associated with it.
Bribery can take place in both the public and private sectors and may involve money or any other financial or non-financial advantage.
4. What is Bribery?
A bribe is any financial or other advantage offered, promised, given, requested or accepted with the intention of inducing or rewarding improper conduct.
Bribery can include:
• cash payments;
• commissions or secret payments;
• excessive gifts;
• inappropriate hospitality;
• holidays or travel;
• employment opportunities;
• personal benefits;
• preferential treatment;
• charitable or political contributions intended to influence a decision;
• inflated or false invoices;
• improper rebates;
• kickbacks; or
• any other advantage intended to influence another person improperly.
A bribe does not need to be accepted for an offence to arise. Offering or promising an improper advantage may itself constitute bribery.
5. Prohibited Conduct
No person acting for or on behalf of SGG may:
• offer, promise or give a bribe;
• request, agree to receive or accept a bribe;
• make an improper payment to secure or retain business;
• offer an improper inducement to a customer, club, supplier, licence holder or public official;
• receive an undisclosed commission or kickback;
• use a third party to make a payment which SGG itself would not be permitted to make;
• disguise improper payments through expenses, invoices, sponsorships or consultancy arrangements;
• falsify records relating to payments, expenses or benefits; or
• retaliate against anyone who raises a genuine concern concerning bribery or corruption.
6. Gifts and Hospitality
SGG recognises that reasonable and proportionate corporate hospitality can form a legitimate part of normal business relationships.
Gifts and hospitality must, however:
• be reasonable and proportionate;
• have a legitimate business purpose;
• not be intended to influence a business decision improperly;
• not create an obligation or expectation of favourable treatment;
• be appropriate to the circumstances;
• comply with applicable laws;
• be accurately recorded where required; and
• be capable of public disclosure without causing embarrassment to SGG.
Cash gifts and cash equivalents must never be offered or accepted.
Particular care must be taken in relation to hospitality involving:
• customers during contract negotiations;
• tender processes;
• licence negotiations;
• prospective acquisition targets;
• public officials; and
• individuals involved in awarding business.
SGG may maintain a Gifts and Hospitality Register, and transactions above limits established by the Board or management must be approved and recorded.
7. Facilitation Payments
SGG prohibits facilitation payments.
Facilitation payments are unofficial payments made to secure or accelerate a routine action to which the payer is already entitled.
Employees and representatives must not make such payments on behalf of SGG.
Where a person believes their health or safety would be placed at genuine risk by refusing a payment, they should prioritise their personal safety and report the incident to SGG as soon as reasonably practicable.
8. Political and Charitable Contributions
SGG does not permit political or charitable contributions to be used as a means of obtaining an improper business advantage.
Any charitable sponsorship or donation made by or on behalf of the Group must:
• be legitimate;
• be appropriately authorised;
• be properly documented; and
• not be linked to the award or retention of business.
9. Sponsorship and Sports Relationships
Given the nature of SGG's business, sponsorships, club relationships, licensing arrangements and sporting partnerships require particular care.
No sponsorship, free product, hospitality, rebate, commission or other benefit may be provided where its purpose is improperly to influence:
• the award of a supply agreement;
• the renewal of a contract;
• a tender;
• a licensing decision;
• procurement;
• a club or federation decision;
• an acquisition; or
• any other business decision.
Commercial arrangements must have a legitimate business rationale and be accurately recorded.
10. Agents, Representatives and Third Parties
SGG may be legally responsible for improper conduct by persons performing services on its behalf.
Appropriate due diligence should therefore be undertaken before appointing significant:
• agents;
• distributors;
• intermediaries;
• consultants;
• overseas representatives;
• acquisition advisers; and
• other third-party representatives.
Relevant contracts should, where appropriate, contain obligations requiring compliance with applicable anti-bribery legislation and this Policy.
Payments to third parties must be commercially reasonable, properly documented and paid through appropriate banking channels.
11. Acquisitions and Joint Ventures
Anti-bribery and corruption risks should form part of SGG's acquisition due diligence.
Where appropriate, the Group will assess:
• the target's compliance culture;
• significant agents and intermediaries;
• unusual commission arrangements;
• public-sector relationships;
• historic allegations or investigations;
• gifts and hospitality practices; and
• any other material corruption risks.
Following an acquisition, SGG will seek to integrate the acquired business into the Group's compliance framework.
12. Books and Records
All Group companies must maintain accurate books and records.
No person may:
• create false or misleading entries;
• conceal the true nature of a payment;
• maintain undisclosed accounts;
• submit false expenses;
• create sham invoices; or
• deliberately misclassify a payment.
Payments and benefits must be accurately recorded and supported by appropriate documentation.
13. Conflicts of Interest
Directors, employees and representatives must avoid situations in which their personal interests conflict, or appear to conflict, with the interests of SGG.
Actual or potential conflicts should be disclosed promptly in accordance with the Group's governance procedures.
14. Raising Concerns
Any person who knows or suspects that bribery, corruption or other improper conduct may have occurred should report the matter promptly.
Concerns may be raised with:
The Chairman
Chief Executive Officer
Finance Director / responsible finance executive
Reports will be treated seriously and, so far as reasonably practicable, confidentially.
SGG will not tolerate retaliation against a person who raises a genuine concern in good faith.
15. Breaches
A breach of this Policy may result in disciplinary action, including dismissal where appropriate.
SGG may terminate relationships with consultants, representatives, suppliers or other third parties who breach this Policy.
Conduct may also be reported to law-enforcement or regulatory authorities where appropriate.
16. Responsibility
The Board has overall responsibility for this Policy.
Senior management is responsible for promoting an appropriate compliance culture and ensuring that controls proportionate to the Group's risk are implemented.
Every person working for or on behalf of SGG has individual responsibility for complying with this Policy.
17. Training and Communication
SGG will communicate this Policy to relevant employees and associated persons.
Risk-based training may be provided to employees and representatives whose roles expose them to heightened bribery or corruption risks.
18. Monitoring and Review
The Group will periodically review its anti-bribery arrangements having regard to:
• the jurisdictions in which it operates;
• acquisition activity;
• third-party representatives;
• significant contracts;
• regulatory developments;
• identified incidents; and
• changes in the Group's risk profile.
This Policy will be reviewed periodically by or on behalf of the Board.
19. Board Commitment
The Board of Sports Global Group Plc considers integrity and ethical business conduct essential to the Group's long-term success.
SGG's position is straightforward:
We compete for business on the quality of our products, services, brands, people and commercial proposition — never through bribery or improper influence.