CODE OF CONDUCT
DAZN’s long-term success is founded on our ability to conduct our business activities with a high level of integrity and ethical standards, and in compliance with all applicable laws, rules, and regulations. Whatever your position is at DAZN, our Company, clients, colleagues, shareholders, and customers depend on you to perform your duties to a high standard of ethics and judgement.
This Code of Conduct is an important resource that sets forth the core principles that govern all DAZN employees, contractors, vendors, and visitors while conducting business or representing the Company. Whilst it does not cover every issue that may arise, we ask that you read and understand the Code of Conduct and comply with any specific policies and practices that apply to your role. Applying the code to our daily decision-making will help us to create the culture we want at DAZN: collaborative, inclusive, and with a high level of integrity. If we fall short of the standards set out here, we must strive to put things right. If we see cause for concern, we all have a duty to speak up. By remaining committed to the behaviours that support our purpose, we believe that we will continue to improve DAZN as a place to work and achieve our vision and mission.
1. POLICY STATEMENT 1.1. DAZN is committed to a working environment where people have clear visibility of the standards and behaviours we expect of them, and to use these behaviours to drive a culture of equality, diversity and high ethical integrity.
1.2. This Policy outlines those principles, behaviours and values, along with examples of where we may see them in a workplace setting.
1.3. We will take appropriate steps to deal with behaviour (whether intentional or unintentional) that results in a breach of this Policy. We will investigate any allegations made and may pursue disciplinary action where such allegations are upheld.
1.4. This policy does not form part of any contract of employment or contract to provide services, and we may amend it at any time.
2.1. Compliance with Laws and Regulations
• We are committed to ensuring that we comply with the requirements of our regulators, legal frameworks and industry standards in all the countries in which we operate.
• We are open and cooperative with our regulators.
• We report and respond promptly in response to questions, including providing relevant documentation and attending interviews.
• We will adhere to all general notifications and the notification of breaches and disciplinary action requirements, including relevant breaches of this global code of conduct (the “Code”).
• We all have a responsibility to be aware of the requirements that apply to our roles, to comply with them, and to seek advice if we are in any doubt.
• If you are unsure about the legal requirements related to your role, seek guidance from your line manager or People Team.
2.2. Respectful and Inclusive Environment
• We value diversity, inclusion, and equity, and believe in treating every individual with respect, regardless of their race, colour, religion, sex, gender identity, sexual orientation, age, disability, national origin, or any other characteristic protected by law.
• Discrimination, harassment, or any form of offensive behaviour will not be tolerated (see our Anti-discrimination, bullying, harassment and third-party harassment policy for further information). 4
• All DAZN employees should foster an inclusive and welcoming atmosphere where diverse opinions and ideas are encouraged.
2.3. Living by DAZN’s Values and Building Our Culture
• We are committed to embodying and promoting the company’s values of being ambitious, brave, inventive, passionate, and supportive.
• We strive to demonstrate ambition by setting high standards for ourselves, continuously seeking improvement, and embracing new challenges with determination and a growth mindset.
• We embrace bravery by speaking up, sharing ideas, and taking calculated risks that lead to innovation and positive change within the organization.
• We foster inventiveness by encouraging creativity, curiosity, and problem-solving, seeking new approaches and solutions to drive progress.
• We exhibit passion by showing enthusiasm, dedication, and a sense of purpose in our work, inspiring and motivating others to achieve their best.
• We cultivate a supportive culture by treating our colleagues with respect, empathy, and kindness, fostering collaboration, inclusivity, and teamwork.
Each employee has a responsibility to uphold and promote these values in their daily interactions, decisions, and contributions to the company’s success. By embracing and living these values, we can collectively build a strong and vibrant company culture that attracts and retains top talent, drives innovation, and enables our long-term growth. By living by and helping to build the company values and culture, we create an environment where every individual can thrive, ideas can flourish, and our shared goals can be achieved.
2.4. Professionalism and Ethical Behaviour
DAZN employees are expected to conduct themselves in a professional and ethical manner at all times. This includes maintaining confidentiality, respecting intellectual property rights, avoiding conflicts of interest, and acting honestly and transparently in all business dealings. Employees must not engage in any activities that may damage the company’s reputation or its relationships with clients, partners, or stakeholders.
All of our colleagues are required to comply with this Code, as well as the policies, procedures, and laws that apply to their particular jurisdictions and role. Everyone is asked to confirm annually that they understand and comply with the Code’s principles. How we behave against these could impact our personal performance ratings and career opportunities within DAZN.
All people managers and senior leaders at DAZN should be seen as role models for their team and, as such, they are expected to set the standard, manage and develop their teams and lead our business, by: 5
- creating an environment that is respectful and inclusive;
- encouraging their team members to speak up – asking for help or raising our concerns is a big part of working for DAZN;
- listening and responding to concerns when they are raised;
- doing their part to make sure that no one experiences retaliation for speaking up or co-operating in an investigation;
- helping team members understand the principles and expectations of our Code, as well as any related rules and regulations;
- being consistent when ensuring team members follow our requirements and holding people accountable for their behaviour at work .
2.4.1. Personal integrity
We all have a basic responsibility to comply with the law, regulations, statutory codes, company policies, and authorisations relevant to our roles. However, acting with integrity is a higher standard. It requires us to think about every action we take – before we take it – to ensure we are acting in the interests of our customers and clients and doing the right thing.
Your contribution is vital to upholding the company’s reputation, and your actions both internally and externally can have an impact on this. We all have a responsibility to make the company aware of important changes in our personal circumstances – such as criminal proceedings or formal financial proceedings – which could impact our roles.
2.4.2. Due skill, care, and diligence
We should all perform our roles with due skill, care, and diligence. Examples of failing to achieve this can vary for each of us depending on our role but could include:
- failing to follow or ignoring processes and procedures;
- failing to properly inform customers, clients, or colleagues of something that could result in a detrimental outcome for them ; or
- undertaking a task, making a recommendation, or providing advice without suitable training and/ or understanding, or conducting an activity when you don’t feel competent or trained. 2.4.3. Responsibility for our own training
It’s important that we all take responsibility for our continuing personal development and are clear about and adhere to the processes and parameters of our role.
Managers also need to ensure that sufficient training, oversight, and performance management is in place to support colleagues in applying due skill, care, and diligence at all times in their roles.
- Anti-competitive Behaviour
- Accurate reporting
- Money Laundering and Financial Crime
- Tax Evasion
- Conflicts of interest
We all need to attain and maintain the competency required to perform effectively in our roles, and to take responsibility for our own personal development. To support this, DAZN provides mandatory training courses to complete when you join the company, and then periodically thereafter in line with the schedule set by the company and what your role requires. We also provide opportunities for training that are relevant to your role. Mandatory training is a requirement of your employment and an important part of our regulatory obligations – it helps demonstrate that you understand the regulatory and conduct requirements of working here.
We take care to avoid practices that may be viewed as anti-competitive – for example, agreeing to charge structures with our competitors.
DAZN is committed to complete, accurate, and timely reporting to the market and relevant authorities, including our regulators. If you are responsible for accounting and financial record-keeping duties, you need to play your part in ensuring that all transactions, funds, assets, revenues, and expenses are accounted for correctly and reported appropriately.
Money laundering is the attempt to hide or disguise the origin of funds to conceal criminal activity. Financial services companies can often be targeted by money launderers. We have a duty to ensure that identity and other checks are conducted for new business relationships including customers and clients, third parties, partners, and suppliers. We can only receive or pay money to individuals and entities that have been suitably identified and verified in accordance with local legal requirements. We value our reputation for financial integrity and reliability, and we’re committed to preventing, detecting, and reporting fraud and developing an anti-fraud culture. If you have any suspicions of money laundering, fraud, or any other financial crime occurring you should report it as per the Anti-Money Laundering policy.
Tax evasion can take different forms, but it’s most commonly seen as the intentional evasion of paying tax due or diverting funds from public revenues. This is a criminal offence and can be committed at an individual or corporate level. It is also an offence to facilitate another party’s actions in evading tax or to fail to put in place reasonable procedures to prevent the facilitation of tax evasion. We need to ensure we all take reasonable measures to avoid facilitating another party’s part in tax evasion and should only work with others who apply the same high standards.
Employees are expected to remain loyal to DAZN and avoid conflicts of interest. A conflict of interest is where DAZN and/or any of its employees are subject to influences that might adversely affect decision-making or outcomes while doing business. They can include situations where a conflict might not actually exist, but where someone believes that one could potentially arise. A conflict can arise from the competition of legitimate influences such as acting for multiple customers or clients, or the presence of potentially harmful ones such as personal gain.
Conflicts generally fit into one of two categories:
- Conflicts that arise while conducting business for DAZN and also our customers or clients. This may include conflicts between the interests of: o our business (or one of its subsidiaries) and those of a customer, client, employee or supplier;
- an employee of DAZN and those of a customer or client;
- one customer or client and those of another; and/or
- one part of our business and those of another.
- Conflicts resulting from personal activities and relationships of employees inside and outside of DAZN, such as: o personal relationships or friendships, including those with suppliers, clients, customers, or colleagues; and/or second jobs, business ventures, outside appointments and/or involvement in public affairs. 126.96.36.199. What are your obligations for managing conflicts of interest
Across our business, we provide a range of customer and client services and play multiple roles. We need to ensure that our decisions and actions always put the best interests of our customers, clients and DAZN first, rather than prioritising our own personal interests.
Any outside employment, business ventures, or financial activities cannot interfere with the performance of your duties to DAZN.
In avoiding conflicts of interest, you must comply with the following principles:
- Do not hold a financial interest in or accept employment from an entity doing business with DAZN if it would or could conflict with the performance of your duties at DAZN;
- Do not take any DAZN business-related action for your personal benefit;
- Protect Company assets as if they were your own;
- Do not take for yourself any opportunities that are discovered or advanced through the use of your position with DAZN or any of DAZN’s property of information;
- No family members or employees that are romantically involved should report directly to each other;
- Do not facilitate a conflict with one of our suppliers, service providers, customers, or any government official, for example, by making a payment to an individual when you know the funds should go to their employer. 188.8.131.52. Disclosing and addressing potential conflict of interest 2.4.9. Outside appointments 184.108.40.206. What are outside appointments?
- What are my obligations in relation to outside appointments? What are the restrictions for taking on outside appointment?
DAZN requires that you disclose, in writing, to either your Line Manager and/or Group Legal any personal, business or other relationship that might constitute a conflict of interest or could potentially create a conflict of interest. Our policy is one of disclosure, review of potential conflicts and prohibition of actual conflicts of interest. In some cases, disclosure may be all that is required. In other cases, however, the facts may require additional action(s) to correct or avoid a conflict of interest. Some matters may require periodic monitoring by local management to ensure transactions remain at arm’s length. In all cases, however, you MUST disclose all actual and potential conflicts of interest.
Outside appointments are any positions you might hold with any organisations outside our company. This includes any voluntary or charitable business appointments, business ventures, and significant ownership of companies.
Make sure you have read and understood your employment/consultancy contract clause relating to outside appointments as these may prevent you from taking a second job or other outside appointment without our company’s consent. Generally, this will involve a discussion with your manager before you accept the position to ascertain whether there is a potential conflict of interest or something that contradicts the terms of your employment/consultancy contract. If you are still unsure after discussing it with your manager, contact your local People Team.
If you do take up such an appointment, remember that you cannot use confidential knowledge gained through your role in our company for an advantage in an outside role, or pass it on to someone who may use it in this way. You must avoid outside appointments which are or could be in conflict with your employment at DAZN.
- 2.4.10. Malpractice, Bribery, And Inducements
- 220.127.116.11. Bribery and Corruption
- 18.104.22.168. Gifts and Hospitality need to ensure that our decisions and actions always put the best interests of DAZN, our customers and clients first.
DAZN takes a zero-tolerance approach to bribes offered or accepted. Bribery is the offer of anything of value toa person – often a public official – but sometimes a private citizen in exchange for that person to provide an undue business or other advantage. Giving, offering, demanding, or accepting a bribe is a criminal offence, with punishments that include substantial fines and prison terms. Bribes often involve direct offers of cash and other assets, but can also include offers of employment, information, charitable donations, meals, entertainment, or travel expenses. Corruption is the abuse of entrusted power for personal gain. It is often associated with public officials seeking money and other valuable things in exchange for breaking rules within their official duties and functions, but it can also happen in the private sector. Certain activities present a heightened risk of bribery and corruption. These include engaging third parties or agents to act on DAZN’s behalf, activities involving higher-risk jurisdictions or public officials, and when giving and receiving gifts and hospitality.
While the exchange of gifts or the provision of hospitality can build goodwill in business relationships, we must always bear in mind that gifts and hospitality can be used to exert improper influence or the appearance of improper influence and might even be viewed as an inducement or bribe. It is therefore important, before offering or accepting gifts or hospitality, that we assess whether it’s appropriate considering who is involved, the relationship and the nature and value of the gift or hospitality. Make sure you are aware of the limits and authorisation requirements within our procedures relevant to your business unit and geography and that you record these kinds of benefits (whether offered or received) on the appropriate register. It’s important that we take care when offering or accepting gifts or hospitality, dealing with political or public officials, and handling expenses. It has a big role to play in building the trust and confidence of our customers and clients, and in protecting our company’s reputation. If we don’t follow the correct procedures, our actions in any of these areas could be perceived as a conflict of interest, an inappropriate inducement or even a bribe.
- 2.5. Confidentiality and Data Protection
Information is one of the most valuable assets. Business records, customer information, financial information, and intellectual property are company assets that are essential to our operations. This information is not available to the public and includes sensitive business information which has been entrusted to us.
We all are responsible for keeping this information confidential. It is important to ensure that those you share such confidential information with, even if another colleague, are entitled to receive that information and that it’s necessary for their role (see the section below entitle “What is my obligation for making sure information remains confidential and secure?” about checking if there is an NDA in place).
Examples of confidential information we may have access to include:
- personal data: information that can be used to directly or indirectly identify an individual is considered ‘personal data’. This can include an individual’s name, email address, home address, bank details, identification documents such as passports and electronic information such as IP address or device ID. More sensitive personal data – or special category personal data – includes health data, sexual orientation, political opinions, or disability information. Personal data of both customers and DAZN staff is processed by the company for different purposes, and both categories should be treated with an equal level of confidentiality and care.
- corporate data: information not publicly available such as Board papers, company results, our intellectual property, commercial pricing information, details of a new proposition to be launched to market with information on volumes and costs, or potential acquisition or disposal of assets, and employee data.
Handling information in the right way is critical to safeguarding our customers, clients, colleagues, and shareholders. It’s also crucial to our reputation, to our financial integrity, and to create the outcomes that clients expect.
You must not use any information belonging to DAZN for your own personal gain. Any unauthorised disclosure of confidential information, whether unintentional or not, must be reported immediately to Group Legal
This Code is not intended to prevent or dissuade employees from engaging in communications or activities protected by the relevant employment laws, such as discussing wages, benefits, or other terms and 11
- 2.6. Using information responsibly 2.6.1. Social Media and Online Conduct
- 2.6.2. What is my obligation for making sure information remains confidential and secure?
Conditions of employment.
This Code also does not prevent employees from disclosing confidential information when required by law or legal process (of course, always subject to advice from Group Legal).
Employees should exercise caution when using social media or other online platforms, especially when discussing company-related matters.
Any content shared publicly should be respectful, accurate, and not disclose confidential or proprietary information.
Employees should refrain from engaging in online behaviour that may harm DAZN’s reputation or damage professional relationships.
When working with or disclosing information, particularly outside DAZN, think carefully about legal and confidentiality requirements and the potential personal or reputational damage that prohibited sharing or an information breach could lead to.
- Always check with Group Legal if there is a non-disclosure agreement (“NDA”) or other restrictions in place between DAZN and the relevant the party as it is important to understand the boundaries in which you will need to operate.
- Do not conduct business communications using your personal email account.
- Do not use social media and messaging apps for business purposes wherever confidential or sensitive information is involved. Wherever possible, use Teams as the messaging app of choice.
- If you do use social media or messaging apps, please converse in a work appropriate manner. These types of communication would be requested as part of disclosure in the event of any legal action, not just emails and formal documents.
- Don’t send confidential information to your personal email account or to an unauthorised third party.
- Any information or documents created for business purposes remain the property of our company. You’re not entitled to remove them from our premises, whether in physical or electronic format, except temporarily for legitimate work purposes.
- If you choose to make your association with our company known when you use personal social media profiles, make it clear that the views you express are your own and do not represent our company’s views.
- Make sure you read and understand the requirements set out in our policies on privacy and data protection, protection of information and resilience, and acceptable use.
- Your contract of employment will also outline any individual obligations relating to confidentiality, as well as adhering to applicable privacy and data protection laws. 2.6.3. What happens if I do not treat information securely and confidentially? 2.6.4. What should I do if I notice that I have (or a colleague has) emailed information to the wrong person?
As well as breaching internal policies and procedures, deliberately and recklessly misusing information can result in disciplinary action leading to possible dismissal, and even criminal or civil enforcement. In most countries, there is an information or privacy regulator with powers to fine individuals and companies who do not protect personal and confidential information.
- You should immediately contact the recipient and advise them that the information has been sent to them in error, that it constitutes confidential information, and ask them to confirm that it has been destroyed securely.
- You should immediately report any actual or suspected incident of theft, unauthorised access/disclosure, or unauthorised misuse of company information to the Service Desk via Security Incident form on the DAZN Service Now platform
- DAZN is obliged to report personal data breaches that are likely to impact the rights and freedoms of individuals to the relevant supervisory authority within 72 hours of becoming aware, so quick notification is imperative.
- Failure to log a breach promptly could result in not only a breach of privacy and data protection laws, but also further harm being caused to those individuals impacted e.g. identity fraud, personal upset, and financial loss. 2.7. Workplace Safety 2.7.1. Employees should promptly report any potential hazards, unsafe conditions, near misses, accidents, or injuries to their supervisor, manager, or Facilities or Property Staff
We are committed to providing a safe and healthy work environment for all employees. It is everyone’s responsibility to comply with applicable health and safety regulations, as well as any company-specific safety policies and procedures. By following health and safety regulations, promoting a safety-conscious culture, and actively identifying and mitigating risks, we can create a secure and healthy workplace for everyone.
- 2.7.2. Employees should actively participate in safety training programs, follow safe work practices, and take appropriate measures to prevent accidents, injuries, and occupational illnesses.
- 2.7.3. Violent, threatening, or aggressive behaviours that compromises workplace safety are strictly prohibited.
- 2.7.4. Employees should cooperate with safety inspections, audits, and investigations conducted by the company or relevant authorities to ensure a safe and compliant work environment
- 2.8. Reporting Violations 2.8.1. If an employee becomes aware of a violation of this Code, they should promptly report it to their line manager, the People Team, or an appropriate designated authority.
- 2.8.2. Reports may be made confidentially or anonymously, and the company will investigate all reports in a fair and unbiased manner.
- 2.8.3. Retaliation against individuals who report in good faith is strictly prohibited.
- 2.8.4. Please, refer to the Whistleblowing policy to get familiar with the procedure to report any breaches of this Code.
- 2.9. Consequences of Non-compliance
It could only take one serious breach of these standards to undo much of our good work. Any action that falls short of the requirements of our this Code or any of our regulators may be dealt with under DAZN’s formal disciplinary procedures.
Depending on the severity and specific circumstances of the breach, disciplinary action could be taken, up to and including dismissal. In the case of contractors and agency workers, any inappropriate conduct could lead to services being ended or suspended.
We may need to inform our regulators of any disciplinary action taken – including formal written warnings, suspension, dismissals, or having to reduce or hold back anyone’s pay as a result of failing to meet our conduct standards.
If you become aware of a breach of our Code and/or a regulatory breach, report this as soon as you can to your manager.
3. Policy Reviews and Updates 3.1. All employees will have access to information and training that relates to this policy, and the policy itself via DAZN Anywhere and our New Starter Hub.
3.2. External partners, contractors, consultants, supporters, and beneficiaries can access the policy via DAZN’s website.
3.3. This policy is subject to periodic review and may be updated or modified at the company’s discretion to ensure its effectiveness and compliance with legal and regulatory requirements.