Sports Global Group Plc
Board approved: 10th of August 2026
Last reviewed: 1st of August 2026
1. Policy Statement
Sports Global Group Plc is committed to complying with applicable economic, financial and trade sanctions.
SGG will not knowingly conduct business in breach of UK sanctions laws or knowingly assist another person to evade or circumvent sanctions.
Given the Group's international sourcing, distribution, licensing, acquisitions and commercial activities, sanctions compliance forms part of our wider financial-crime and risk-management framework.
2. Scope
This Policy applies to:
• Sports Global Group Plc;
• controlled subsidiaries;
• Directors;
• employees;
• agents;
• representatives;
• distributors;
• contractors; and
• other persons acting on behalf of the Group.
3. UK Sanctions
As a UK-incorporated group, SGG is required to comply with applicable UK sanctions legislation.
UK sanctions may restrict dealings involving:
• designated persons;
• designated entities;
• particular countries or territories;
• certain goods;
• particular technologies;
• financial services;
• trade services;
• shipping or transport;
• specified sectors; and
• particular end uses.
Sanctions may include asset freezes, trade restrictions and prohibitions on making funds or economic resources available to designated persons.
4. International Operations
Where SGG conducts business outside the United Kingdom, additional sanctions regimes may also apply.
The Group will consider relevant local requirements and, where appropriate, the effect of other applicable sanctions regimes.
Where legal requirements conflict or are unclear, the transaction should not proceed until appropriate advice has been obtained.
5. Risk-Based Approach
Sanctions risk varies according to:
• country;
• counterparty;
• ownership;
• products;
• destination;
• end user;
• distribution channels;
• payment route; and
• transaction structure.
SGG therefore adopts a proportionate, risk-based approach.
6. Counterparty Due Diligence
Depending upon transaction risk, SGG may conduct checks on:
• customers;
• suppliers;
• manufacturers;
• distributors;
• agents;
• acquisition targets;
• investors;
• beneficial owners;
• banks; and
• other material counterparties.
Checks may include sanctions-screening against relevant UK lists and examination of ownership or control where necessary.
7. Ownership and Control
A counterparty which is not itself named on a sanctions list may nevertheless be subject to restrictions because it is owned or controlled by a designated person.
Where relevant, SGG will seek to understand ultimate ownership and control before proceeding.
8. Trade Sanctions
Employees involved in sourcing, exporting, importing or distributing products must consider whether:
• the destination is subject to trade restrictions;
• the goods are restricted;
• the end user is sanctioned;
• the intended end use is prohibited;
• an export or sanctions licence is required; or
• routing through another jurisdiction creates circumvention risk.
9. Sanctions End-Use Risk
SGG will not knowingly supply goods where the Group has been informed, or has reasonable grounds for concern, that the transaction involves a prohibited sanctioned end use.
Relevant employees should escalate unusual requests regarding:
• end user;
• destination;
• re-export;
• product description;
• routing; or
• final use.
10. Payments
Payments must not knowingly be made to, received from, or made available for the benefit of a sanctioned person where prohibited.
Employees should be alert to:
• unusual intermediary banks;
• unexplained third-party payers;
• requests to change payment destinations;
• payment routes involving high-risk jurisdictions;
• virtual or alternative payment arrangements designed to obscure origin; and
• attempts to split transactions.
11. Circumvention
SGG prohibits deliberate attempts to circumvent sanctions.
No person may structure a transaction for the purpose of avoiding sanctions that would otherwise apply.
Examples may include:
• routing goods through another jurisdiction to hide their final destination;
• disguising the identity of the end user;
• using intermediaries to transact with a sanctioned person;
• falsifying documentation; or
• altering payment routes to conceal a prohibited counterparty.
12. Red Flags
Possible sanctions warning signs include:
• reluctance to disclose beneficial ownership;
• unexplained corporate structures;
• transactions inconsistent with the customer's business;
• unusual destinations or re-export routes;
• last-minute changes to customers, destinations or banks;
• use of intermediaries with no clear commercial purpose;
• requests to remove identifying information from documentation;
• payment from unrelated third parties; or
• adverse sanctions or enforcement information.
A red flag does not automatically mean a transaction is prohibited, but it requires appropriate investigation.
13. Acquisitions
Sanctions compliance should form part of SGG's acquisition due diligence where relevant.
This may include review of:
• target-company ownership;
• international customers and suppliers;
• sanctioned territories;
• counterparties;
• banking relationships;
• historic breaches;
• export activity; and
• product end use.
Material concerns must be escalated before completion.
14. Licensing and Exceptions
Certain activities otherwise restricted by sanctions may be permitted under a statutory exception or government licence.
No employee may assume that an exception or licence applies.
Where a licence may be required, the Group will seek appropriate advice and obtain the necessary authorisation before proceeding.
15. Reporting Concerns
Suspected sanctions breaches or attempted circumvention should be reported immediately to:
The Chairman
Chief Executive Officer
Finance Director / responsible finance executive
The transaction should be paused where appropriate pending review.
16. External Reporting
Where applicable law requires or makes appropriate a report to a competent authority, SGG will make or consider making the relevant notification.
This may include engagement with:
• the Office of Financial Sanctions Implementation (OFSI);
• the Office of Trade Sanctions Implementation (OTSI);
• HM Revenue & Customs;
• law-enforcement authorities; or
• other competent bodies.
Professional legal advice should be obtained where appropriate.
17. Record Keeping
SGG will retain appropriate records supporting higher-risk sanctions decisions, which may include:
• screening results;
• due-diligence information;
• ownership information;
• contracts;
• licences;
• shipping records;
• payment documentation; and
• approvals.
18. Training
Relevant employees involved in:
• finance;
• procurement;
• sourcing;
• imports and exports;
• logistics;
• international sales;
• acquisitions; and
• senior management
may receive sanctions-awareness training proportionate to their responsibilities.
19. Breaches
A breach of sanctions law can carry serious civil and criminal consequences.
Breaches of this Policy may result in disciplinary action, termination of commercial relationships and referral to relevant authorities.
20. Review
Sanctions regimes change frequently.
This Policy and associated procedures should therefore be reviewed periodically and following significant changes to:
• SGG's geographical operations;
• supply chains;
• acquisition strategy;
• sanctions legislation; or
• identified risk.
21. Board Commitment
Sports Global Group Plc is committed to conducting international business responsibly.
The Group will not knowingly pursue commercial opportunity at the expense of sanctions compliance.
Where there is uncertainty, the correct approach is to stop, investigate and obtain appropriate advice before proceeding.