Dated: July 2026
Anti-Tax Evasion Facilitation Policy
Anti-Facilitation of Tax Evasion Policy Statement
DAZN Group Holdings Ltd. and the subsidiaries under its direct control (together “DAZN” and individually each a “Group Company”) are fully committed to complying with all legislation and applicable guidelines, whether under UK law or the law of any foreign country, designed to prevent tax evasion and the facilitation of tax evasion in the jurisdictions in which we, our clients, our suppliers and our business partners operate.
It is the policy of DAZN to conduct all of our business in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and to implementing and enforcing effective systems to counter the facilitation of tax evasion.
At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.
This policy document is endorsed by senior management and sets out DAZN’s policy for preventing the facilitation of tax evasion (the “Policy”) and the standards and procedures required to ensure compliance with the Policy.
1. Introduction
1.1 The United Kingdom’s Criminal Finances Act 2017 (the “CFA”) introduced the corporate criminal offence of failure to prevent the facilitation of tax evasion which effectively makes companies vicariously liable for the actions of their employees and other ‘Associated Persons’ who facilitate tax evasion. Consequently, if as a corporate group, we fail to prevent our employees, workers, service providers or agents from facilitating tax evasion, we can face criminal sanctions including an unlimited fine, as well as exclusion from tendering for public contracts and damage to our reputation.
1.2 At DAZN, we take these legal responsibilities seriously and have adopted the above policy statement (the “Policy Statement”) summarising our corporate values in relation to the anti-facilitation of tax evasion, in addition to the more detailed analysis and explanation of our practices below.
1.3 We ask that all our employees and all those who have, or seek to have, a business relationship with any of DAZN familiarise themselves with our anti-tax evasion Policy and act at all times in a way which is consistent with our Policy Statement.
1.4 The purpose of this Policy is to:
(a) set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on preventing the criminal facilitation of tax evasion; and
(b) provide information and guidance to those working for us as to how to recognise and avoid tax evasion.
2. Scope of this Policy
2.1 This Policy applies to all persons working for DAZN or on behalf of DAZN in any capacity, wherever located, and therefore includes employees at all levels, directors, officers, agency workers, seconded workers, volunteers and interns (together “Associated Persons”).
2.2 DAZN also encourages the application of this Policy amongst entities outside of its direct control, such as its business partners, including its joint venture partners (“Business Partners”).
2.3 DAZN also requires all persons such as agents, contractors, intermediaries, suppliers and distributors, external consultants or any other person who performs services for or on our behalf (“Third-Party Associated Persons”) to be made aware of this Policy and to act in a way that is consistent with this Policy or any equivalent Policy that they may themselves have.
2.4 Section 12 below sets outs how the Policy specifically applies to Business Partners and Third-Party Associated Persons.
2.5 In this Policy, “Third-Party” means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisers, representatives and officials, politicians and political parties.
3. The offence of facilitating tax evasion
3.1 The offences under the CFA relate to the pre-existing offences of: (1) tax evasion; and (2) the facilitation of tax evasion:
3.1.1 Tax evasion is the offence of fraudulently evading tax and is a criminal offence. It requires an element of fraud which means that there must be deliberate action or omission with dishonest intent. The offence is therefore committed where a person is knowingly concerned in or takes steps to fraudulently reduce the amount of tax they should otherwise have paid, i.e., they deliberately and dishonestly evade tax. For example, by deliberately and dishonestly failing to declare income.
3.1.2 The facilitation of tax evasion is a separate criminal offence and is committed where a person is knowingly, i.e., deliberately and dishonestly, concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, or aiding, abetting, counselling or procuring the commission of that offence. For example, by setting up an offshore account to enable the taxpayer to avoid tax.
3.2 It is important to note the distinction between tax evasion, which is illegal, and tax avoidance, which is not. Tax avoidance involves the taking of steps within the law to minimise tax payable or maximise tax reliefs and is not caught under the CFA.
3.3 Historically, to be guilty of either offence, the offender would have needed to be knowingly involved in the tax evasion or facilitation of tax evasion. Under the CFA, however, a criminal offence is automatically committed by a corporate entity or partnership where the tax evasion is facilitated by a person acting in the capacity of an “associated person” to that organisation (which would include DAZN’s Associated Persons, Business Partners and Third-Party Associated Persons as defined above). Therefore, whilst any such person associated with DAZN must deliberately and dishonestly take action to facilitate the tax evasion by the taxpayer, DAZN itself does not have to have deliberately or dishonestly facilitated the tax evasion; it is a strict liability offence and DAZN’s facilitation of that offence simply by failing to take reasonable precautions to prevent its occurrence creates a liability for DAZN. If the “associated person” accidentally, ignorantly, or negligently facilitates the tax evasion, then the corporate offence will not have been committed by DAZN.
3.4 The tax evasion that can be the subject of the offence under the CFA can be either the evasion of UK tax or the evasion of foreign tax and therefore there are two offences: (i) the failure to prevent facilitation of UK tax evasion and (ii) the failure to prevent facilitation of overseas tax evasion (together, the ‘Tax Evasion Offences’).
3.5 The UK offence occurs where an “associated person” of DAZN (when acting as such) facilitates UK tax evasion, i.e., such person commits an offence which under UK law consists of: (i) being knowingly concerned in, or in taking steps with a view to, the fraudulent evasion of a tax by another person; (ii) aiding, abetting, counselling or procuring the commission of a UK tax evasion offence; or (iii) being involved in the commission of an offence consisting of being knowingly concerned in, or in taking steps with a view to, the fraudulent evasion of a tax.
3.6 The foreign offence has two limbs. It occurs where:
3.6.1 An “associated person” of DAZN (when acting as such) facilitates foreign tax evasion, i.e., such person facilitates the evasion of tax in a foreign country, provided that such conduct: (i) is an offence under the law of that country; (ii) relates to the commission by another person of a tax evasion offence under the law of that country; and (iii) would be a criminal offence if committed in the UK, and
3.6.2 one of the following apply:
(a) the relevant body (being DAZN, in this case) is incorporated or formed in the UK;
(b) the relevant body (being DAZN, in this case) carries on business, or part of a business, in the UK; or
(c) any conduct constituting part of the foreign tax evasion facilitation takes place in the UK.
4. Risk mitigation
4.1 We have undertaken a risk assessment and identified that the following are particular risks for our business:
4.1.1 DAZN engages at scale in multiple business operations across multiple jurisdictions. This geographical spread, combined with the broad range of commercial and contractual arrangements, decreases the level of visibility and stress tests even the strongest control framework, increasing the challenge of consistently implementing and monitoring the controls in place to protect our customer and supply chains.
4.1.2 DAZN operates a flexible workforce model, with both staff and an extended workforce contributing to customer delivery which can increase the risk of Tax Evasion Offences being committed. It is important that all those acting on behalf of DAZN, regardless of employment status and working practices, are familiar with, and adhere to, DAZN processes and policies that apply to their practice area.
4.1.3 As would be expected of a large international group with multiple revenue streams, the DAZN corporate structure contains subsidiaries and substantive operations across multiple jurisdictions, as well as joint ventures (“JVs”), all of which heighten the risk of Tax Evasion Offences.
4.2 In order to address the risks of tax evasion and the facilitation of tax evasion we have undertaken a CFA risk assessment across the DAZN group and put in place processes to address risks identified. The measures include ensuring that:
4.2.1 all staff at every level have read this Policy and understand the nature of the Tax Evasion Offences;
4.2.2 training is provided to staff as appropriate, both as part of the onboarding process and thereafter, in order to enable them to identify and report tax evasion. In particular, bespoke tailored supporting documentation will be provided to certain departments plus regular updates and reminders;
4.2.3 the below red flag list continues to be reviewed and developed in order to help Associated Persons identify risks in practice;
4.2.4 appropriate onboarding policies and procedures, including research and robust due diligence, are carried out by DAZN before engaging with any Third-Party (as defined below) that will become an Associated Person or Third-Party Associated Person or Business Partner;
4.2.5 all sources of financing are subject to checks regarding the source of funds;
4.2.6 payments made by DAZN are only ever paid to and from recognised accounts that have been subject to a due diligence process;
4.2.7 finance staff are subject to appropriate senior oversight to prevent any deviations from DAZN’s policies and procedures (including this Policy);
4.2.8 there is ongoing support from the in-house tax department to the business to provide special technical advice on key risk areas, including external finance, intra group transactions and employment tax advice (via the global payroll and rewards team); and
4.2.9 a reporting structure is established to enable you to escalate concerns in respect of any potential risk in relation to Tax Evasion Offences (see sections 7 and 8 below).
5. Prevention guidelines for you as an Associated Person
5.1 As an Associated Person, it is not acceptable for you (or someone on your behalf) to:
5.1.1 engage in any form of activity, practice or conduct in the course of your work which would constitute facilitating UK or foreign tax evasion;
5.1.2 aid, abet, counsel or procure the commission of UK tax evasion offence or foreign tax evasion offence by another person;
5.1.3 fail to promptly report any request or demand from any Third-Party to facilitate the fraudulent evasion of tax (whether UK tax or foreign tax), or any suspected fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, in accordance with this Policy;
5.1.4 engage in any other activity that might lead to a breach of this Policy; or
5.1.5 threaten or retaliate against another individual who has refused to commit a UK tax evasion offence or a foreign tax evasion offence or who has raised concerns under this Policy.
6. Your responsibilities as an Associated Person
6.1 You must ensure that you read, understand and comply with this Policy.
6.2 The prevention, detection and reporting of UK and foreign tax evasion are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
6.3 You must notify your manager as soon as possible if you believe or suspect that a conflict with this Policy has occurred or may occur in the future.
6.4 The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns related to UK or foreign tax evasion. The list is not intended to be exhaustive and is for illustrative purposes only and may be amended from time to time.
6.5 If you encounter any of these red flags while working for us, you must report them promptly using the procedure set out in the Whistleblowing Policy:
6.5.1 you become aware, in the course of your work, that a Third-Party has made or intends to make a false statement relating to tax, has failed to disclose income or gains to, or to register with, HMRC (or the equivalent authority in any relevant non-UK jurisdiction), has delivered or intends to deliver a false document relating to tax, or has set up or intends to set up a structure to try to hide income, gains or assets from a tax authority;
6.5.2 you become aware, in the course of your work, that a Third-Party has deliberately failed to register for VAT (or the equivalent tax in any relevant non-UK jurisdiction) or failed to account for VAT;
6.5.3 you become aware, in the course of your work, that a Third-Party working for us as an employee asks to be treated as a self-employed contractor, but without any material changes to their working conditions;
6.5.4 a supplier or other subcontractor is paid gross when they should have been paid net;
6.5.5 a Third-Party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
6.5.6 a Third-Party requests that payment is made to a country or geographic location different from where the Third-Party resides or conducts business;
6.5.7 a Third-Party to whom we have provided services requests that their invoice is addressed to a different entity, where we did not provide services to such entity directly;
6.5.8 a Third-Party to whom we have provided services asks us to change the description of services rendered on an invoice in a way that seems designed to obscure the nature of the services provided;
6.5.9 you notice that we have been invoiced for a commission or fee payment that appears too large or too small, given the service stated to have been provided;
6.5.10 you appoint or accept advice from Third-Party professional advisers that are not well recognised and/or without appropriate checks on their credibility;
6.5.11 you provide financial assistance in terms of favourable terms for particular investors/lenders without sound commercial reason;
6.5.12 you receive an invoice from a Third-Party that appears to be non-standard or customised;
6.5.13 a Third-Party insists on the use of side letters or refuses to put terms agreed in writing or asks for contracts or other documentation to be backdated;
6.5.14 a Third-Party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
6.5.15 you accept funds from investors or lenders without appropriate due diligence that would help them move money around or hide taxable income or assets in order to help their clients evade tax liability; or
6.5.16 you do not have sufficient support and controls to ensure that Associated Persons, both within the UK and overseas act in line with this Policy (in so far as DAZN is able to exercise control over such individuals) in terms of engaging with clients, lenders or investors.
7. Raising concerns
7.1 DAZN maintains a policy of ‘stand up and speak’ in relation to any concerns. You are encouraged to raise concerns about any issue or suspicion of tax evasion or foreign tax evasion (or any intention to evade tax) at the earliest possible stage.
7.2 If you become aware of any actual or attempted fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person in the course of your work, or you are asked to assist another person in their fraudulent evasion of tax (whether directly or indirectly), or if you believe or suspect that any fraudulent evasion of tax has occurred or may occur, whether in respect to UK tax or tax in a foreign country, the details of the parties and the transaction must be reported as soon as possible in accordance with our Whistleblowing Policy.
7.3 If you are unsure about whether a particular act constitutes tax evasion or foreign tax evasion, raise it with your manager as soon as possible. You should note that a CFA Offence is only committed where you deliberately and dishonestly take action to facilitate the tax evasion or foreign tax evasion. If you do not take any such action, then a CFA Offence will not be made out. However, a deliberate failure to report suspected tax evasion or foreign tax evasion, or “turning a blind eye” to suspicious activity could amount to criminal facilitation of tax evasion.
8. Whistleblowing
8.1 Individuals who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.
8.2 We are committed to ensuring no one suffers any detrimental treatment (as defined in paragraph 8.3 below) as a result of:
8.2.1 refusing to take part in, be concerned in, or facilitate tax evasion or foreign tax evasion by another person;
8.2.2 refusing to aid, abet, counsel or procure the commission of a tax evasion offence or a foreign tax evasion offence by another person; or
8.2.3 reporting in good faith their suspicion that an actual or potential tax evasion offence or foreign tax evasion offence has taken place or may take place in the future.
8.3 For the purposes herein, detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform a representative from the People Team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure, which can be found on our internal website.
9. Training
9.1 Training in respect of this Policy forms part of the induction process for all individuals who work for DAZN, and ongoing regular training will be provided as necessary. Such training may form part of wider financial crime detection and prevention training or, where appropriate, may be bespoke training to address specific tax risks identified by DAZN’s risk assessments.
9.2 Such training will impart an understanding of the scope of the Tax Evasion Offences and the associated risks and will inform participants of how to seek advice and raise concerns. The training will be in line with government guidance, “Tackling tax evasion: Government guidance for the corporate offences of failure to prevent the facilitation of tax evasion” and will cover, as a minimum, the following topics:
9.2.1 An explanation of an employee’s duty under the CFA;
9.2.2 DAZN’s policies and procedures in respect of the Tax Evasion Offences, as contained herein;
9.2.3 An explanation of when and how to seek advice and report any concerns or suspicions of tax evasion or wider financial crime, including information on DAZN’s whistleblowing procedures; and
9.2.4 An explanation of the term “tax evasion” and associated fraud.
9.3 DAZN will ensure that mandatory training on this Policy is offered to those employees, workers and any Associated Persons who have been identified as being at risk of exposure to criminal tax evasion, at least once every year and, in any case, where the Board deems it necessary following a risk assessment. The content and structure of such training will be tailored to reflect the nature of the relationship between DAZN and the Associated Person, i.e. taking into account the level of control, proximity and supervision DAZN is able to exercise over a particular Associated Person and will be proportionate to the level of risk identified.
10. Consequences for breach of Policy
10.1 Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
10.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy.
11. Status of Policy
This Policy does not form part of any employee’s contract of employment, and we may amend it at any time.
12. Prevention Guidelines for Business Partners and Third-Party Associated Persons
12.1 DAZN recognises that it has and will continue to have a diverse range of different business relationships with Business Partners and Third-Party Associated Persons, who are not Associated Persons and are not strictly under their control.
12.2 Whatever the relationship however, DAZN is committed to acting in accordance with the key principles outlined above and will therefore take the appropriate steps in each case to ensure that it has assessed that risk. Whilst the Policy cannot be prescriptive about how such risks will be addressed in any particular case of Business Partners or Third-Party Associated Parties, DAZN will ask for cooperation with DAZN in putting in place appropriate measures to address risk. This may include:
(a) Business Partners or Third-Party Associated Parties confirming that you have received and read this Policy;
(b) Business Partners or Third-Party Associated Parties confirming that you have in place equivalent policies to prevent the facilitation of tax evasion by your Associated Persons, Business Partners and Third-Party Associated Persons and will comply with these when acting for or on behalf of DAZN;
(c) Business Partners or Third-Party Associated Parties providing information or assistance to enable DAZN to assess any risk in relation to its business relationship with you or to carry out due diligence in relation to their business (to the extent that this is necessary in order to address any risk); and/or
(d) Business Partners or Third-Party Associated Parties entering into contractual provisions to provide assurance to DAZN that such party will act in accordance with the law or with the terms of this Policy.
13. Responsibility for the Policy
13.1 The board of directors (the “Board”) has committed itself to this Policy and its implementation across the DAZN group.
13.2 The Board has overall responsibility for ensuring that this Policy complies with DAZN’s ongoing legal and ethical obligations and that all Associated Persons comply with this Policy.
13.3 Each Head of Department has primary and day-to-day responsibility for implementing this Policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure that DAZN is effective in preventing the facilitation of tax evasion.
13.4 Each Head of Department will conduct periodic risk assessments of their department, including a review of their department’s policies, business practices, culture, customer trends and the conduct of the department’s Associated Persons and make reasonable and proportionate adjustments to Policy to correspond to their risk level determination. Risk assessments may also be prompted by market developments or the identification of any potential concerns with respect to potential criminal activities.
13.5 Each Head of Department will keep a record of their risk assessments, training, investigations and any actions taken by their department and/or DAZN in response to their findings. They will share their findings with other Heads of Department and the Board.
13.6 Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate and regular training on it.
13.7 You are invited to comment on this Policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the relevant Head of Department or to the Tax Team at dazn_tax@dazn.com. The Heads of Department/Tax Team will be responsible for collating such comments and feeding back to the Board as appropriate.