Sports Global Group Plc
Board approved: 10th of August 2026
Last reviewed: 1st of August 2026
1. Purpose
Sports Global Group Plc expects everyone working for or representing the Group to conduct business with integrity, professionalism and respect.
This Code sets the minimum standards of conduct expected across SGG.
It applies alongside more detailed Group policies and procedures.
2. Our Principles
Our business conduct is based upon:
Integrity
We act honestly and ethically.
Accountability
We take responsibility for our decisions and actions.
Respect
We treat colleagues, customers, suppliers and partners fairly and professionally.
Compliance
We comply with applicable law and Group policies.
Commercial Discipline
We protect the assets, reputation and long-term interests of SGG.
Transparency
We maintain accurate records and communicate honestly.
3. Compliance with Law
All Directors, employees and representatives are expected to comply with applicable laws and regulations.
No commercial objective justifies unlawful conduct.
Where an employee is uncertain about a legal or regulatory requirement, the matter should be escalated before action is taken.
4. Bribery and Corruption
SGG prohibits bribery and corruption.
Employees and representatives must comply with the Group's Anti-Bribery & Corruption Policy.
No person may offer or accept an improper payment, kickback or benefit in order to secure business or an improper advantage.
5. Financial Crime and Sanctions
SGG will not knowingly facilitate money laundering, fraud, terrorist financing or sanctions evasion.
Employees must comply with the Group's:
• Anti-Money Laundering & Financial Crime Policy; and
• Sanctions Policy.
6. Conflicts of Interest
All Directors and employees must avoid situations in which personal interests conflict or may appear to conflict with the interests of the Group.
Potential conflicts must be disclosed promptly in accordance with the Conflicts of Interest Policy.
7. Gifts and Hospitality
Reasonable hospitality can form part of normal business relationships, but it must never be used improperly to influence decisions.
Gifts and hospitality must be:
• reasonable;
• proportionate;
• transparent;
• lawful; and
• consistent with Group policy.
Cash gifts must not be offered or accepted.
8. Fair Competition
SGG competes vigorously but fairly.
Employees must not engage in:
• unlawful price fixing;
• bid rigging;
• market sharing;
• improper exchange of competitively sensitive information; or
• other anti-competitive conduct.
9. Customers and Partners
We aim to deal honestly and professionally with:
• clubs;
• customers;
• consumers;
• licensors;
• suppliers;
• agents;
• distributors; and
• business partners.
Representations concerning products, pricing, capabilities or contractual commitments must be accurate.
10. Product Quality and Safety
The Group seeks to supply products that comply with applicable quality, labelling and product-safety requirements.
Concerns regarding defective, unsafe or non-compliant products must be escalated promptly.
11. Human Rights and Modern Slavery
SGG respects internationally recognised human rights.
The Group will not knowingly tolerate forced labour, trafficking, unlawful child labour or serious labour exploitation.
Employees must comply with the Group's Modern Slavery & Human Trafficking Policy.
12. Equality, Dignity and Respect
SGG seeks to maintain workplaces free from unlawful discrimination, harassment, bullying and victimisation.
Employment decisions should be based upon legitimate business requirements, capability, performance and merit.
13. Health and Safety
Everyone working within the Group has a responsibility to take reasonable care of health and safety.
Employees must comply with relevant health-and-safety policies, procedures and instructions.
Unsafe practices should be reported promptly.
14. Confidential Information
Employees and Directors may have access to commercially sensitive or confidential information.
Such information must:
• be used only for legitimate business purposes;
• be protected against unauthorised disclosure;
• not be used for personal advantage; and
• remain confidential after employment or appointment ends where legally required.
15. Inside and Price-Sensitive Information
Individuals who receive confidential or potentially price-sensitive information concerning SGG must treat it with particular care.
Such information must not be:
• disclosed without authority;
• used for personal advantage;
• selectively shared with investors or third parties; or
• used in connection with securities dealing contrary to applicable law or Group policy.
16. Company Property and Resources
Group assets must be used responsibly.
This includes:
• money;
• inventory;
• IT systems;
• intellectual property;
• confidential information;
• vehicles;
• equipment;
• corporate credit cards; and
• other company resources.
Fraudulent, excessive or personal misuse may result in disciplinary action.
17. Books and Records
All financial and business records must be accurate and complete.
No person may knowingly:
• falsify an invoice;
• create fictitious transactions;
• manipulate accounting records;
• conceal liabilities;
• misstate stock;
• create false expenses; or
• destroy records improperly.
18. Data Protection and Cyber Security
Personal and confidential information must be handled in accordance with applicable law and Group procedures.
Employees must take reasonable steps to protect:
• passwords;
• systems;
• personal information;
• customer data; and
• commercially sensitive information.
Suspected data breaches or cyber incidents must be reported immediately.
19. External Communications
Only authorised individuals may speak publicly on behalf of SGG.
Public statements, investor communications, media comments and social-media activity relating to Group business must be accurate and must not improperly disclose confidential or price-sensitive information.
20. Raising Concerns
Employees who suspect wrongdoing should raise the issue through:
• management;
• the appropriate compliance contact; or
• the Whistleblowing Policy.
Retaliation for genuine reporting is prohibited.
21. Breaches
Breaches of this Code may result in disciplinary action, termination of employment or commercial relationships and, where appropriate, referral to relevant authorities.
22. Leadership Responsibility
Directors and managers are expected to lead by example.
They should promote a culture in which:
• ethical conduct is expected;
• concerns can be raised;
• financial controls are respected; and
• commercial pressure is never used to justify improper behaviour.
23. Our Standard
SGG's reputation is built through the conduct of everyone representing the Group.
We expect our people to ask a simple question when making decisions:
Is it lawful, ethical, transparent and in the long-term interests of Sports Global Group and its stakeholders?
If the answer is uncertain, the matter should be escalated before proceeding.