Sports Global Group Plc
Last reviewed: 1st of September 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 in a lawful, ethical and transparent manner.
The Group will not knowingly facilitate money laundering, terrorist financing, fraud, sanctions evasion, handling the proceeds of crime or other financial crime.
SGG maintains a zero-tolerance approach to knowingly participating in or facilitating financial crime.
The Group will take proportionate steps to understand the identity and legitimacy of the organisations and individuals with whom it conducts significant business and will investigate unusual or suspicious transactions where appropriate.
2. Scope
This Policy applies to:
• Sports Global Group Plc;
• all subsidiaries controlled by SGG;
• Directors and officers;
• employees;
• contractors;
• consultants;
• representatives; and
• other persons acting on behalf of the Group where appropriate.
3. Regulatory Position
Sports Global Group Plc is principally engaged in sportswear, teamwear, fanwear, licensing, e-commerce, logistics and related commercial activities.
The Group does not represent that it is a regulated financial institution or that all of its activities fall within the regulated sector for the purposes of the UK's Money Laundering Regulations.
Nevertheless, SGG recognises that all businesses can potentially be exposed to money laundering and other financial crime.
The Group therefore adopts proportionate controls designed to reduce the risk of its businesses, bank accounts, commercial arrangements or corporate structures being used for unlawful purposes.
Where any Group activity becomes subject to specific anti-money laundering supervision or regulation, the relevant Group company will comply with the additional requirements applicable to that activity.
4. What is Money Laundering?
Money laundering is the process through which criminals seek to conceal, disguise, convert, transfer or legitimise proceeds derived from criminal activity.
It may involve:
• receiving criminal property;
• transferring or converting criminal proceeds;
• concealing ownership or origin of funds;
• using legitimate businesses to disguise criminal transactions;
• purchasing goods with illicit funds;
• moving funds through multiple entities or jurisdictions; or
• becoming involved in an arrangement facilitating another person's control of criminal property.
Money laundering may involve transactions that appear legitimate when considered individually.
5. Financial Crime
For the purposes of this Policy, financial crime may include:
• money laundering;
• terrorist financing;
• fraud;
• bribery and corruption;
• tax evasion facilitation;
• sanctions evasion;
• false accounting;
• fraudulent invoices;
• identity fraud;
• misuse of corporate structures;
• dealing with proceeds of crime; and
• other dishonest or unlawful financial conduct.
6. Risk-Based Approach
SGG adopts a proportionate, risk-based approach to financial crime.
Higher levels of scrutiny may be appropriate where transactions involve:
• unusually large sums;
• unexplained third-party payments;
• complex ownership structures;
• high-risk jurisdictions;
• cash transactions;
• unusual payment routes;
• newly formed entities with little apparent commercial history;
• payments from accounts unrelated to the contractual counterparty;
• politically exposed persons where relevant;
• sanctioned territories or counterparties;
• unusual commissions;
• substantial advance payments;
• acquisitions or investments; or
• transactions lacking a clear commercial rationale.
7. Know Your Counterparty
Before entering significant commercial relationships, SGG may undertake reasonable checks to establish:
• the legal identity of the counterparty;
• company registration details;
• registered address;
• trading history;
• ownership or control where relevant;
• the identity of key representatives;
• bank account details;
• the commercial rationale for the transaction; and
• any material sanctions, legal or reputational concerns.
The level of due diligence should be proportionate to the nature, value and risk of the relationship.
8. Acquisitions
Acquisition activity presents particular financial-crime risks.
As part of acquisition due diligence, SGG may consider:
• ownership and beneficial ownership;
• source and legitimacy of material funding where relevant;
• tax and accounting history;
• unusual transactions;
• undisclosed liabilities;
• related-party transactions;
• allegations of fraud or financial misconduct;
• sanctions exposure;
• anti-bribery matters;
• litigation and investigations; and
• other financial-crime risks.
Material concerns should be escalated to the Board and appropriate professional advisers.
9. Customer and Supplier Payments
Where reasonably practicable:
• payments should be made and received through recognised banking channels;
• payments should correspond with contractual arrangements;
• payments should normally be made to the contracting entity;
• unexplained payments to unrelated third parties should be investigated;
• unexplained overpayments should not automatically be returned to a different account;
• unusual refund requests should be scrutinised; and
• invoices should accurately describe the underlying goods or services.
10. Cash Transactions
SGG's preference is to conduct material business through recognised banking and electronic-payment systems.
Group businesses should avoid substantial cash transactions wherever reasonably practicable.
Any unusually large or unexplained cash transaction should be referred to senior management before acceptance.
Where a Group business conducts activities which bring it within any statutory definition of a high-value dealer or other regulated category, the Group will obtain appropriate professional advice and comply with any registration, due diligence, record-keeping and reporting requirements that apply.
11. Red Flags
Employees should be alert to circumstances including:
• a customer unwilling to disclose its identity;
• payments from unrelated individuals or entities;
• requests to split payments without commercial justification;
• unexplained use of offshore companies;
• requests to misdescribe goods or services on invoices;
• substantial overpayments followed by refund requests;
• unusual urgency surrounding payments;
• attempts to circumvent normal approval processes;
• payments involving sanctioned or high-risk jurisdictions;
• unexplained intermediary commissions;
• requests to pay into personal bank accounts;
• reluctance to provide routine corporate documentation;
• transactions materially inconsistent with the customer's normal business; or
• arrangements with no clear commercial purpose.
The presence of a red flag does not necessarily establish wrongdoing but should prompt appropriate enquiry.
12. Sanctions
SGG will seek to comply with applicable UK sanctions laws and other sanctions requirements applicable to its operations.
Where appropriate, the Group may screen significant counterparties, owners or transactions against relevant sanctions information.
Transactions involving a sanctioned person, entity, territory or asset must not proceed where prohibited by law.
Potential sanctions issues must be referred immediately to senior management and appropriate legal advisers.
13. Fraud
SGG does not tolerate fraud by employees, Directors, suppliers, customers or other third parties.
Suspected fraud should be reported promptly and may be investigated internally, through external advisers or by relevant authorities.
No employee should knowingly falsify:
• invoices;
• expenses;
• purchase orders;
• contracts;
• accounting entries;
• payment instructions;
• stock records; or
• other corporate documentation.
14. Record Keeping
The Group will maintain records appropriate to its commercial activities and legal obligations.
Relevant records may include:
• contracts;
• invoices;
• payment information;
• due-diligence documentation;
• bank information;
• approvals;
• correspondence; and
• supporting documentation concerning significant transactions.
Records must not knowingly be falsified, concealed or destroyed for an improper purpose.
15. Suspicious Activity
Any employee or representative who becomes aware of circumstances suggesting possible money laundering or financial crime should report the matter promptly to:
The Chairman
Chief Executive Officer
Finance Director / responsible finance executive
Employees should not attempt to conduct their own investigation beyond reasonable checks required in the course of their role.
Management will determine whether specialist legal, accounting, banking or other advice is required and whether any matter should be referred to an appropriate authority.
16. Confidentiality
Potential financial-crime concerns should be handled carefully and shared only with persons who need the information for legitimate compliance, legal or management purposes.
Employees should avoid informing a suspected wrongdoer of internal concerns or enquiries where doing so could prejudice an investigation or breach applicable law.
17. Responsibilities
The Board has overall responsibility for maintaining appropriate financial-crime controls.
Senior management is responsible for ensuring that procedures appropriate to the Group's activities and risks are implemented.
Employees are responsible for:
• complying with this Policy;
• remaining alert to unusual activity;
• following financial controls;
• maintaining accurate records; and
• reporting concerns promptly.
18. Training
Relevant employees may receive financial-crime awareness training appropriate to their responsibilities and the risks associated with their roles.
Employees working within finance, acquisitions, international operations, procurement or other higher-risk functions may receive more detailed training.
19. Breaches
A breach of this Policy may result in disciplinary action, including dismissal where appropriate.
The Group may terminate relationships with customers, suppliers, agents, representatives or other counterparties where serious financial-crime concerns arise.
Where appropriate, matters may be reported to law-enforcement, regulatory or other relevant authorities.
20. Review
This Policy will be periodically reviewed to reflect:
• changes to the Group's activities;
• international expansion;
• acquisitions;
• changes in applicable law;
• changes in financial-crime risk;
• regulatory guidance; and
• experience arising from incidents or investigations.
21. Board Commitment
Sports Global Group Plc is committed to ensuring that its businesses are not knowingly used to facilitate the proceeds of crime or other unlawful financial activity.
Our approach is based upon integrity, proportionate due diligence, accurate financial records, appropriate controls and prompt escalation of genuine concerns.