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. PRINCIPLES

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.

  1. Anti-competitive Behaviour
  2. Accurate reporting
  3. Money Laundering and Financial Crime
  4. Tax Evasion
  5. 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. 2.4.8.2. 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. 2.4.8.3. Disclosing and addressing potential conflict of interest 2.4.9. Outside appointments 2.4.9.1. 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
  • 2.4.10.1. Bribery and Corruption
  • 2.4.10.2. 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:

  1. 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.
  2. 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.

Antidiscrimination

INTRODUCTION

 Welcome to the global anti-discrimination, bullying, harassment and third-party harassment policy. This policy is here to help us all understand what certain unacceptable behaviours look like – it explains what discrimination, bullying and harassment are, and the steps you can take to report or take action if you see any of these things taking place. We all have a role to play in making DAZN a great place to work for all our colleagues worldwide, so please read through this Policy and help us take DAZN forward together.

 

 

  1. POLICY STATEMENT

 

1.1 DAZN is committed to a working and learning environment where people can achieve their full potential free from any form of discrimination, harassment or bullying, and is committed to providing an inclusive culture of equality, diversity and respect between individuals.

 

1.2 This Policy outlines DAZN’s vision of creating and maintaining a healthy environment where our people are confident that any complaints raised by them in relation to any form of discrimination, harassment and bullying will be dealt with fairly, diligently and promptly. DAZN is committed to early intervention and to provide a supportive culture which encourages the reporting of such incidents or behaviours.

 

1.3 At DAZN, we recognise the need to challenge any tacit or explicit acceptance of discrimination, harassment or bullying; to educate employees on what these could look like, and to provide the right tools and processes to report and deal with any instances of discrimination, harassment or bullying.

 

1.4 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.

 

1.5 This policy does not form part of any contract of employment or contract to provide services, and we may amend it at any time.

 

 

  1. SCOPE

 

2.1 This policy applies to any person working with or for DAZN (this includes employees, consultants, contractors, partners, volunteers, interns, freelancers, and job applicants) worldwide regardless of their seniority or length of service.

 

2.2 However, depending on the territory in which employees are located, there may be additional local laws and regulations that apply or supersede the information here. It is the responsibility of each individual to familiarise themselves with and adhere to the relevant local laws and regulations. If you are unsure about the legal requirements related to your role, seek guidance from your line manager or People Team.

 

 

  1. PRINCIPLES

 

3.1 All members of DAZN should help to:

 

  • prevent discrimination, harassment and bullying by being sensitive to the reactions and needs of others, and ensuring that their conduct does not cause offence;
  • discourage discrimination, harassment and bullying by others by making it clear that such conduct is unacceptable, and supporting colleagues and peers who are taking steps to stop it; and
  • understand what constitutes discrimination, harassment and bullying by attending training sessions and/or seeking advice from your local People Team.

 

3.2 DAZN is responsible for:

 

  • taking reasonable steps to eliminate discrimination, bullying and harassment as well as to actively promote equality to provide a collegiate and harmonious working environment; discourage discrimination, harassment and bullying by others by making it clear that such conduct is unacceptable, and supporting colleagues and peers who are taking steps to stop it;
  • implementing training for employees in relation to discrimination, harassment and bullying; and
  • raising awareness to help colleagues identify and deal with discrimination, harassment and bullying.

 

3.3 All line managers and others with positions of responsibility have an additional obligation to:

 

  • ensure that this Policy is implemented;
  • promote equality and an inclusive and non-discriminatory environment; and
  • tackle swiftly and fairly any discrimination, harassment and bullying that is reported to them.

 

3.4 Unacceptable behaviour is not necessarily confined to the behaviour of senior staff towards more junior staff; it can take place between individuals at the same level or staff behaving inappropriately towards more senior members of the company. Harassment, bullying and discrimination can also take place on the internet and through the misuse of email, social media and other digital channels. This can include but is not limited to the use of social media including X/Twitter, Facebook, Instagram, LinkedIn, WhatsApp, YouTube, Reddit, TikTok, Snapchat and other platforms, as well as chat rooms and other forums, personal web pages, emails, text messages, Skype, conference calling and other online tools.

 

 

  1. DEFINITIONS

 

Bullying: bullying refers to any form of verbal or non-verbal unwanted behaviour from a person or group that is either offensive, intimidating, malicious or insulting or an abuse or misuse of power that undermines, humiliates, or causes physical or emotional harm to someone.

 

Discrimination: discrimination is treating a person or particular group of people differently, especially in a worse way from the way in which you treat other people, because of their race, gender, sexuality, disability or any other protected characteristic.

 

Harassment: harassment refers to any unwanted conduct or behaviour on the grounds of gender, sexual orientation, disability, age, race, nationality, ethnic origin, religious or philosophical beliefs which has the purpose or effect of violating the dignity of the person at whom it is aimed or creating an intimidatory, hostile, degrading, humiliating or offensive environment for that person. It is recognised that it is not the intention of the perpetrator that is the key in deciding whether harassment has occurred, but whether the behaviour is unacceptable by normal standards and disadvantageous and how it makes the recipient feel.

 

Sexual Harassment: sexual harassment refers to unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect of violating the dignity of the person at whom it is aimed or creating an intimidatory, hostile, degrading, humiliating or offensive environment for that person.

 

Third-party Harassment: third-party harassment refers to the harassment of DAZN employees by people (third parties) who are not employed by DAZN, such as suppliers, clients and customers. Additionally, DAZN can also be held liable if our employees behave inappropriately towards people who are not directly employed by DAZN.

 

4.1 Harassment and bullying are serious disciplinary offences and incidents may be treated as gross misconduct under DAZN’s disciplinary procedure. A single incident can amount to harassment or bullying if sufficiently grave.

 

4.2 Sexual or racial harassment and age discrimination at work is unlawful and both DAZN and the harasser may be held liable. Intentional racial or sexual harassment and age discrimination is also a criminal offence, punishable by a fine or imprisonment.

 

4.3 We’ve included more details in the Appendix, where you’ll find further examples of discrimination,

bullying and harassment.

 

 

  1. REPORTING DISCRIMINATION, HARASSMENT, VICTIMISATION AND BULLYING

 

5.1 If you believe that you have been subject to unlawful workplace discrimination or bullying and harassment of any kind or have observed discrimination or bullying and harassment of another employee, you should report the matter as soon as possible.

 

5.2 Given the sensitivity of discrimination, bullying and harassment allegations, the purpose of this

procedure is to help to resolve those complaints in a swift and sensitive way.

 

Informal reporting

 

5.3 Where it is possible and where there is no risk to safety, we at DAZN would always encourage informal action to help the alleged perpetrator understand the impact of their actions and offer them an opportunity to change. This may involve asking if the reporting individual is willing to talk with the alleged perpetrator and explain the impact of their actions. If an individual is confident and able to inform the alleged perpetrator that they find the behaviour directed against them unacceptable and they ask them to stop, this may well resolve the situation (especially if the action was unintentional). However, we appreciate that isn’t always possible, either due to the individual not feeling comfortable, or due to the severity of the action. Whether resolved informally or not, a written record should be kept of all incidents including the details, dates, times, circumstances, and witnesses.

 

Formal reporting

 

5.4 If the matter is not resolved or the behaviour persists, then an individual should approach their line manager and/or their local People Team Representative. Where an allegation is brought forward to be considered formally, DAZN will conduct confidential and impartial investigations. There are several factors we will take into account when deciding whether conduct is discrimination, harassment or bullying:

 

  • the seriousness of the case;
  • the evidence provided; and
  • the alleged reporting individual’s perception of the conduct.

 

5.5 DAZN will take into consideration any aggravating factors (such as unacceptable behaviour arising from an abuse of power from an individual who is in a senior position against an individual who is in a junior position, for example). Where an allegation is upheld, this may normally result in disciplinary action which can include dismissal, expulsion or potentially referral to the police.

 

5.6 If the alleged perpetrator is the reporting person’s manager, they should contact their People Team Representative.

 

5.7 Under normal circumstances, we at DAZN would expect such a complaint to be made at the earliest possible opportunity. Historic events will be investigated where possible, although we encourage employees to come forward as early as possible. The individual approached when reporting will, in the first instance, provide support and assistance and any complaint will be treated sensitively, seriously, and confidentially.

 

5.8 As a general principle, the decision whether to progress a complaint is up to you. However, we have a duty to protect all staff and may pursue the matter independently if, in all the circumstances, we consider it appropriate to do so. This may vary depending on local legislation.

 

5.9 We will arrange a meeting with you, usually within one week of receiving your complaint, so that you can give your account of events. You have the right to be accompanied by a colleague of your choice, who must respect the confidentiality of the investigation. Individuals not involved in the complaint or the investigation should not be told about it.

 

Investigations

5.10 Complaints will be investigated in a timely, respectful and confidential manner. A Manager, People Team Representative or where appropriate, a senior leader unconnected with the allegations, will conduct an independent and objective investigation.

 

5.11 Where your complaint is about an employee, we may consider suspending them on full pay or making other temporary changes to working arrangements pending the outcome of the investigation, if circumstances require. The investigator will also meet with the alleged harasser or bully who may also be accompanied by a colleague to hear their account of events. They have a right to be told the details of the allegations against them, so that they can respond.

 

5.12 Where your complaint is about someone other than an employee, such as a customer, supplier or visitor, we will consider what action may be appropriate to protect you and anyone involved pending the outcome of the investigation, bearing in mind the reasonable needs of the business and the rights of that person. Where appropriate, we will attempt to discuss the matter with the third party.

 

5.13 We will also seriously consider any request that you make for changes to your own working arrangements during the investigation. For example, you may ask for changes to your duties or working hours to avoid or minimise contact with the alleged harasser or bully.

 

5.14 It may be necessary to interview witnesses to any of the incidents mentioned in your complaint. If so, the importance of confidentiality will be emphasised to them.

 

5.15 At the end of the investigation, the investigator will submit a report to a senior manager. The senior manager will arrange a meeting with you, usually within a week of receiving the report, in order to discuss the outcome and what action, if any, should be taken. You have the right to bring a colleague to the meeting. A copy of the report and the senior manager’s findings will be given to you and to the alleged harasser.

 

Action following the investigation

 

5.16 When a complaint is upheld, the severity of the penalty imposed upon the individual(s) found guilty of discrimination, bullying or harassment will be in line with DAZN’s disciplinary procedures. If the disciplinary investigation does not result in termination, then the penalties we impose may be coupled with actions to ensure that the person who has reported the issue is able to continue working without embarrassment or anxiety. These actions may include (where job or business requirements allow):

 

  • moving the perpetrator to another place or post;
  • providing the option of moving the victim to another place or post; and/or
  • some form of mediation and/or counselling.

 

Any action taken will be subject to it being reasonable and practicable given the normal operational requirements of DAZN.

 

Criminal offences

 

5.17 If the person reporting considers that they may have been subjected to conduct at work amounting to a criminal offence (such as a sexual assault) they may request that their Line Manager assists with making a formal complaint to the relevant local authorities to provide any other assistance they may require.

 

Malicious and/or vexatious allegations

 

5.18 Disciplinary action may be taken if allegations are found to be malicious or vexatious – this is where people put forward false allegations with the specific intention of damaging another individual.

However, individuals will not be subject to disciplinary action or any other detrimental treatment simply because their complaint is not upheld and will only face disciplinary action if it is found both that the allegation is false and made in bad faith (that is, without an honest belief in its truth).

 

 

  1. CONFIDENTIALITY AND DATA PROTECTION

 

6.1 DAZN will at all times comply with local data protection legislation. Any information provided in relation to harassment, discrimination and/or bullying shall be kept confidential and will only be shared with others within DAZN on a ‘need to know’ basis. There may be instances where DAZN may have to disclose confidential information to the police (where in exceptional circumstances DAZN considers that there is a high risk of continuing harm to the reporting individual or others within the company or to prevent a further incident which constitutes a criminal offence from occurring), the civil and criminal courts if requested formally.

 

 

 

  1. TRAINING AND AWARENESS

 

7.1 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.

 

7.2 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.

Equal Opportunity

DAZN recognises that it is essential to provide equal opportunities to all persons without discrimination. This policy sets out the organisation’s position on equal opportunity in all aspects of employment, including recruitment and promotion, giving guidance and encouragement to employees at all levels to act fairly and prevent discrimination on the grounds of sex, race, marital status, part-time and fixed term contract status, age, sexual orientation, or religion.

 

1. POLICY STATEMENT

1.1. It is the policy of DAZN to ensure that no job applicant or employee receives less favourable treatment on the grounds of sex, race, marital status, disability, age, part-time or fixed term contract status, sexual orientation, or religion, or is disadvantaged by conditions or requirements that cannot be shown to be justifiable. DAZN is committed not only to its legal obligations but also to the positive promotion of equality of opportunity in all aspects of employment.

1.2. DAZN acknowledges that adhering to the Equal Opportunities Policy, combined with relevant employment policies and practices, maximises the effective use of individuals in both DAZN’s and employees’ best interests. DAZN recognises the great benefits of having a workforce with diverse backgrounds, employed solely on ability.

1.3. The application of recruitment, training, and promotion policies to all individuals will be on the basis of job requirements and the individual’s ability and merits.

1.4. All employees of DAZN will have access to the provisions of this policy.

1.5. 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. SCOPE 2.1. The policy applies to all aspects of employment including:

  • Job applicants and potential applicants
  • Employees
  • Fixed Term Contract
  • Contract or Agency workers
  • Casual workers
  • Freelancers
  • Trainee workers and students on work experience or placements
  • Former employees

2.2. The policy also applies to advertisement of jobs, conditions of work, pay and other terms and conditions of employment. Staff will be treated equally regarding opportunities for equal pay, promotion, training, or transfer.

3. RECRUITMENT AND PROMOTION

3.1. Advertisements for posts will give sufficiently clear and accurate information to enable potential applicants to assess their own suitability for the post based on skills and abilities. Information about vacant posts will be provided in such a manner that does not restrict its audience in terms of sex, race, marital status, disability, age, part-time or fixed term contract status, sexual orientation, or religion.

3.2. Recruitment literature will not imply a preference for one group of applicants unless there is a genuine occupational qualification that limits the post to this particular group, in which case this must be clearly stated.

3.3. We aim to advertise all vacancies internally, though this may not be possible in every circumstance or for every role. Advertising roles internally will help maximise equality of opportunity and provide more staff with opportunities for career development, thus maintaining the skills and expertise of existing staff. In exceptional circumstances, we may waive the need to advertise internally.

3.4. All descriptions and specifications for posts will include only requirements that are necessary and justifiable for the effective performance of the job.

3.5. All selection will be thorough, conducted against defined criteria and will deal only with the applicant’s suitability for the job. Where it is necessary to ask questions relating to personal circumstances, these will be related purely to job requirements and asked to all candidates.

3.6. Where there are business critical roles and roles identified that support DAZN’s business continuity, succession coverage will be planned, suitable candidates will be identified, and their development will be supported to enable future promotions where applicable.

4. EMPLOYMENT

4.1. DAZN will not discriminate on the basis of sex, race, marital status, disability, age, part-time or fixed term contract status, sexual orientation, or religion in the allocation of duties between employees employed at any level with comparable job descriptions.

4.2. DAZN will put in place any reasonable measures and/or adjustments within the workplace for those employees who become disabled during employment or for disabled appointees.

4.3. DAZN will support our employees by allowing flexible working when feasible and reasonable to those employees who are carers, and where it aligns with the needs and demands of the business.

4.4. When practical and feasible, DAZN will accommodate annual leave taken as part of religious holidays. Many DAZN offices include quiet spaces/ wellbeing rooms that can be used for praying practices or other personal commitments.

4.5. All employees will be considered solely on their merits for career development and promotion with equal opportunities for all.

4.6. All employees can become members of our Employees Resource Groups (ERGs) which support under-represented groups and allies. For more information on ERGs please visit ERGs : BE PART OF THE SOLUTION. If you are interested in starting a new ERG, please contact DEI@dazn.com

4.7. DAZN will strive to continually review processes and practices regarding recruitment, ratings, and promotions to ensure efficacy in tackling biases in decision-making and to avoid unjustifiable wage gaps for employees performing similar work.

 

5. TRAINING

5.1. Employees will be provided with appropriate training regardless of sex, race, marital status, disability, age, part-time or fixed term contract status, sexual orientation, or religion.

5.2. All employees will be encouraged to discuss their career prospects and training needs with their Line Manager or the HR Department/People Team.

5.3. All employees will be given access to the DAZN training catalogue, the Learning Zone, to enable all employees to pursue their own individual learning (this covers permanent employees, but not our extended workforce).

 

6. GRIEVANCES AND VICTIMISATION

6.1. DAZN emphasises that discrimination is unacceptable conduct which may lead to disciplinary action under the organisation’s Disciplinary Procedure.

6.2. Any complaints of discrimination, harassment and bullying will be pursued through the organisation’s Grievance Procedure.

6.3. Please, refer to other DAZN’s policies if necessary.

 

7. TRAINING AND AWARENESS OF THIS POLICY

7.1. 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.

7.2. 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.

Whistleblowing in DAZN – Italian Branch

The changes introduced by Legislative Decree No. 24/2023

Last March, Italian Legislative Decree No. 24/2023 (“Decree”), which transposed Directive (EU) 2019/1937 into Italian law, entered into force. Thus, a “general” legal safeguard was introduced for the protection of persons who report violations of national and EU regulations that harm the public interest or the integrity of the public administration or private entity, of which they have become aware in a public or private employment context.

The Decree broadens the subject matter of the reports, extends the range of reporting persons to whom the protections provided for therein apply, identifies the reporting channels, details the procedures for handling reports, and protects the confidentiality of the identity of the reporter, the reported person and other persons involved.

DAZN has adopted a procedure for handling and receiving reports and has also adopted reporting channels that guarantee the confidentiality of the reporter and the persons involved, in order to ensure full compliance with the Decree and to promote maximum transparency within the organization.

On this page, you can find information on the channels, procedures and prerequisites for making internal reports to DAZN, as well as for making external reports to the National Anti-Corruption Authority (‘ANAC’).

What can be reported in DAZN?

The violations that can be reported in the context of DAZN are as follows:

a)    Violations of Italian Legislative Decree 231/2001, for example:
•    Market manipulation, insider dealing.
•    Corporate offences (e.g. false corporate communications or unlawful distribution of profits).
•    Tax offences (e.g. failure to declare or destruction of accounting documents).
•    Violations of the Organization, Management and Control Model adopted at DAZN.

b)    Violations of EU law, for example:
•    Deceptive or aggressive business practices (e.g. misleading advertising).
•    Provision of digital services not in conformity with the consumer contract.
•    Unlawful processing of personal data (e.g. e-mails sent without the consent of the persons concerned).

The complete list of reportable violations is set out in Article 2 (1)(a) of the Decree.
Reports may also concern well-founded suspicions concerning violations committed or which, on the basis of concrete elements, could be committed, as well as elements concerning conduct aimed at concealing such violations.

It is not possible to report disputes, claims or requests linked to an interest of a personal nature on the part of the reporting person or relating to his or her individual employment relationship or to his or her employment relationship with hierarchically superior figures, in the manner indicated herein.

Who Can Report

Under the Decree, reports may be made by:
1)    DAZN employees, even during the probationary period.
2)    self-employed persons, consultants, suppliers, freelancers working with or for DAZN.
3)    volunteers and trainees.
4)    shareholders and persons with administrative, management, control, supervisory functions at DAZN.

The persons indicated may also make reports before the commencement or after the termination of the employment relationship, provided that the information on the reported violations was acquired in the course of the relationship.

DAZN’s internal reporting channels

DAZN has set up internal reporting channels in compliance with the Decree, aimed at guaranteeing the confidentiality of the identity of the person making the report, the person involved, and the person mentioned in the report.
The internal reporting channels are as follows:
1)    IT platform, accessible at the following link: https://dazn.integrityline.com. The platform also provides the possibility of sending voice messages.
2)    By postal service to: Gestione segnalazioni whistleblowing- Piazza San Babila 3 20122 Milano;
3)    At the request of the reporter, through a direct meeting with the office dedicated to receiving and handling reports (Case Manager).

If the postal service is used, in order to ensure confidentiality, it is necessary to put the report in two sealed envelopes: the first with the identity data of the reporter together with a photocopy of the identification document; the second with the report, so as to separate the identity data of the reporter from the report. Both envelopes should be placed in a third sealed envelope, which should be marked on the outside “Strictly confidential.

Confidential to the Case Manager’. The whistleblower should indicate in the communication an address where he/she can prove receipt of the report and provide feedback. To ensure confidentiality, it is recommended to use addresses from which the identity of the reporter cannot be traced.
The management of reports

DAZN has entrusted the reception and management of reports to the functions XXX (‘Case Managers’), appropriately trained to ensure the confidentiality of the reporter and other persons involved.
The case manager will carry out the verification activities necessary to follow up the report, possibly with the help of other previously authorized persons, and will manage the dialogue with the reporter.

In any case, in order to ensure proper handling, reports must be accurate, circumstantiated and supported by evidence. The submission of untruthful, defamatory and slanderous reports is prohibited; violation of this prohibition may lead to the imposition of sanctions against the reporter.

Reports with different subject matter should follow the specific contact channels provided.
External reports

For alerts concerning breaches of EU law, an external alert may be issued if the following conditions are met:
1)    the whistleblower has already made an internal report and it has not been followed up.
2)    the whistleblower has reasonable grounds to believe that, if he or she were to make an internal report, it would not be effectively followed up or that the report might give rise to the risk of retaliation.
3)    the reporter has reasonable grounds to believe that the breach may constitute an imminent or obvious danger to the public interest.

The addressee of the external report is the Italian National Anti-Corruption Authority (ANAC), which will carry out the necessary investigative activity to follow up the report. To learn more about the channels, methods and management of reports by ANAC, please refer to the following link:
https://www.anticorruzione.it/-/whistleblowing