Board of Directors of Brentford FC Limited:

The club is committed to running our business in an ethical and lawful manner and has a zero-tolerance approach to slavery in all its forms. Each of our contracts with third parties, including within our supply chain and our partners, include a requirement for them to comply with all applicable laws including those relating to anti-slavery and human trafficking. This ensures that modern slavery is not taking place anywhere within our business or within our supply chain or that of our partners.

Our supply chains include a number of suppliers of goods and services, which support our business including both our football operations and commercial operations. Key suppliers that we identified as part of our risk assessment in 2023 were the club’s apparel partner and our food and beverage partners. We also have several other commercial partners with whom we are directly associated with. Most of our agreements with these companies includes a specific requirement for them to abide by our club policies. For suppliers and/or partners who are manufacturers of apparel and/or clothing or food and beverages, we have the right to conduct risk assessments and ethical audits. We are committed to carrying these out periodically for those suppliers and partners in business sectors where modern slavery and exploitation is a higher risk.

When the club selects new suppliers and partners, we undertake a risk assessment and due diligence process which includes a review of the company’s modern slavery policy. Where a risk assessment identifies a particular area of concern, the club undertakes a more detailed review of the specifics of that organisation’s own policy to ensure it meets our standards. If the club does not believe that a supplier or partner is working to our required standards, we will insist that the company in question make necessary changes to their business practices before we enter into a contract with them. If they don’t make the necessary changes or that they are unable to, we will withdraw from those discussions. Likewise, should the club become aware that an existing supplier or partner is no longer working to our required standards, we will insist that the company in question make necessary changes to their business practices and if they don’t make necessary changes or that they are unable to, we will seek to terminate our contract.

Recruitment Policy

The club Recruitment and Selection Policy and Procedure was last updated in August 2025 and provides a clear framework for safely recruiting and selecting appropriately experienced, suitable and qualified workers fairly and transparently. We are also committed to preventing harm by ensuring that no unsuitable person works with children or vulnerable adults.

All staff need to have characteristics and values that make them safe and suitable to work at the club. To ensure this, some actions we take in line with our safer recruitment processes include:

• Ensuring all prospective staff are subject to criminal record checks (Disclosure Barring Service) and a Self-Declaration Form in accordance with the requirements of their respective roles

• Completing a risk assessment of any information revealed within the safer recruitment process (for example, content within a DBS certificate). If there is disagreement about the outcome of a risk assessment, a DBS panel will be convened. This would be chaired by the Operational Risk Director

• Candidates completing an application form, including the applicants’ background and job history – we will not just accept a CV

• Interviewing applicants with a diverse panel and recording recruitment decisions

• Safeguarding-related interview questions asked and gaps in employment history checked

• Obtaining at least two references, including from the most recent employer

• Undertaking online searches (including social media screening) over relevant roles

• Verifying and recording applicant’s qualifications and experience on a single central record

• Verifying and recording employees’ right to work documentation to ensure they have a right to work in the UK

• Providing staff with an induction to their role, including safeguarding policies and procedures and accredited safeguarding training

• Ensuring all staff complete a probationary period

• No one being able to start regulated activity until all checks are cleared

The recruitment process is overseen by the People team at the club who will ensure that any recruitment completed by the Club, in partnership with the Safeguarding Team when needed, is done safely.

Code of Conduct

The club Code of Conduct was last updated in August 2023, and exists to clarify the standards of conduct expected from all staff, players, Board members, Trustees, volunteers, temporary staff and agency workers (staff) at Brentford FC and BFC CST, promote consistency, ensure that all staff are aware of their responsibilities whilst engaged in their employment and to set out the implications of non-compliance.

Whistleblowing

We have a Whistleblowing Policy in place set out in the company’s employee policies portal which allows employees to help us tackle corruption and crime, including modern slavery.

Employees of Brentford FC, our suppliers, and anybody connected with us, are encouraged to speak up if they have concerns about any aspect of our business. Our Complaints Policy is set out in the Supporter Charter. If anyone wishes to contact us about alleged slavery in our business or within our supply chain, concerns can be raised to the club directly at [email protected] or alternatively, a complaint can be addressed to the club’s adjudicator who is the Chair of the Board of Brentford Football Community Society Limited “Bees United” and also a director of the club.

If any complainant wishes to whistleblow to an organisation that is completely independent of the club they may do so by contacting Protect, an independent charity which supports whistleblowers and lobbies for protection for whistleblowers. The club is a member of Protect, and they may be contacted on +44 20 3117 2520 or [email protected].

We expect our supply chain to operate fair and equitable practices, whereby modern slavery is not tolerated. The club acknowledges the importance of a strong due diligence framework supporting its policies. We've initiated efforts to enhance our existing due diligence systems, aligning them with our approach to effectively mitigate risks related to modern slavery. Any revisions to our applicable current policies and procedures will be communicated to our suppliers accordingly.

Due diligence procedures will be proportionate to the identified modern slavery risk, the severity of the risk, and level of influence a business may have. This will be informed by the broader risk assessments which have been conducted. For technology suppliers (especially those with offshore operations or subcontractors), the club will review and complete an in depth risk review.

The Club has a robust risk assessment and management process in place across all aspects of its operations. This is supported by a comprehensive Risk Register, which is prepared and maintained by the Operational Risk Director and his team, drawing on inputs from across the Club and representing all departments. The Risk Register identifies the areas of the business most exposed to risk and includes the identification and assessment of specific risks relating to modern slavery and human trafficking within the Club’s own operations, its suppliers and further down the supply chain.

The Risk Register is reviewed on a regular basis, including at every Board meeting and at meetings of the Club’s dedicated Risk Committee, which is chaired by a Board Non-Executive Director. These reviews ensure that existing risks remain appropriately managed, emerging or changing risks are identified promptly, and proportionate safeguards are implemented to mitigate the risk of exploitation, forced labour or trafficking.

The Club’s risk management framework is fully in use and embedded across the organisation. This framework ensures that risks relating to modern slavery and human trafficking are systematically identified, assessed, monitored and, where necessary, escalated through appropriate governance channels. This enables timely and effective action to be taken to address risks and reinforces the Club’s commitment to preventing modern slavery in all aspects of its business and supply chain.

In order to assess the effectiveness of the measures taken by the club we will continue to regularly review and refine our policies and procedures in relation to modern slavery and human trafficking and will include updates on any actions we take in future statements.

Last year, all staff received mandatory training on Bystander Intervention and reporting safeguarding concerns. During the coming year, the club will introduce mandatory modern slavery training for all staff as part of the rollout of its new HR system, which incorporates an enhanced learning and development platform. The training will be designed to raise awareness of modern slavery and human trafficking, support colleagues in recognising potential indicators of exploitation, and reinforce the club’s commitment to safeguarding. Enhanced and role-specific training will also be provided to colleagues with safeguarding responsibilities, including senior leaders, to ensure they understand the appropriate internal escalation processes and how to refer potential victims to the National Referral Mechanism where required.

We are working on ensuring that care is taken to ensure that key individuals involved in procurement, compliance and legal, commercial sales and operations are aware of how to reduce risk in their areas both for our own operations and that of key suppliers and partners. The club operates a strict policy for the recruitment of staff, which includes mandatory, pre-employment right to work checks.

The club will review and publish this statement annually.

Approval

This statement was approved by the Board of Brentford FC Limited on 29 December 2025. It will be available from the club’s home page at https://www.brentfordfc.com/en/modern-slavery from 29 December 2025 and on the Government’s Modern Slavery Statement Registry here: https://modern-slavery-statement-registry.service.gov.uk/ on or before 31 December 2025.

Signed on the Board’s behalf for and on behalf of Brentford Football Club Limited:

Nity Raj

Director & General Counsel

Brentford FC Limited

29 December 2025