modern slavery

Brentford FC Limited

Modern Slavery Act 2015

December 2025

Financial Year-End: 30 June 2025

Modern Slavery Act Statement Publication: 29 December 2025

“At Brentford Football Club our unwavering commitment to the highest standards of governance, integrity and respect for human rights is deeply rooted in our core values: togetherness, respectful and progressive. We recognise we have a crucial role in combatting modern slavery in all its forms. By fostering a culture of transparency and accountability, we not only adhere to our legal obligations but also uphold our moral responsibility. As a club we pledge to be a force for positive change not just in football but as a leader in our global community.”

Jon Varney, Chief Executive Officer, Brentford FC

Introduction

Modern slavery, including criminal exploitation, domestic servitude, forced labour, human trafficking, and sexual exploitation, is a profound global issue, affecting an estimated 50 million people around the world.

Brentford Football Club Limited (the “club”) is committed to doing what we can to identify, assess, address, and prevent modern slavery and to protect people from exploitation. At Brentford FC, we place inclusivity and safeguarding at the heart of everything we do, and we will not tolerate modern slavery or human trafficking in our organisation, among our partners or in our supply chain.

The club’s values of togetherness, respectfulness, and progressiveness underpin how we address the risks of modern slavery. In accordance with these values, we are committed to acting professionally and conducting our business in an honest and ethical manner. It is of particular concern for our industry as every club has significant relationships with suppliers and partners with global supply chains.

We employ young people, and many people are employed by the club directly or indirectly on a match-by-match basis and it is important that they are treated fairly by us or our suppliers and partners.

In accordance with Section 54 of the Modern Slavery Act 2015, companies with a turnover of £36 million or above must publish an annual statement regarding modern slavery within six months after the end of their financial year. Pursuant to that requirement, the club is publishing our Modern Slavery Act statement in respect of its financial year ending 30th June 2025.

This statement will be updated every year to:

  • act transparently and disclose information about any modern slavery risks we have identified and what actions we have taken in response to them;

  • target our actions where they can have the most impact by prioritising our risks;

  • make year-on-year progress to address those risks and improve outcomes for workers in our business and supply chains.

About Brentford FC

Brentford FC is a professional Premier League football club based in the London Borough of Hounslow. We play our home matches at the Gtech Community Stadium. The club was founded in 1889 and we are now in our fifth season in the Premier League.

In 2020, we moved to a new 17,250-seater stadium with outstanding facilities for fans, broadcasters, corporate guests, and the community, having previously played at our historic Griffin Park home for 116 years. At the end of the first season in the new stadium, Brentford won promotion to the Premier League. This represented the club’s first season in the topflight of English football since 1947 started in August 2021. Promotion and a move to a new stadium are parts of a longer-term vision that aims to see the club sustain top level football on the field and ensure that the club is sustainably run.

Situated next to the M4, the new stadium is at the centre of the Brentford East redevelopment scheme, which includes the construction of more than 900 new homes and a new purpose-built location for Brentford FC Community Sports Trust.

The Brentford FC Community Sports Trust (the “BFC CST”) is the club’s official charity. With community work spanning more than three decades, the BFC CST has established itself as a pioneering organisation for the local community using the power of sport to educate, motivate and inspire people from all backgrounds.

The BFC CST and the club work together to take a very active role in the local community. The club and the trust have worked together to win the EFL Community Club of the Year Award four times and the Club has also been awarded a Business in the Community and Community Mark Award. In total, since the opening of the new stadium in 2020, the BFC CST impacts in the local area have been valued at £143 million in that three-year period. In 2025, the BFC CST launched a new apprenticeship for the industry titled ‘Changing the Game’ backed by the Premier League and PFA which aims to enhance the national workforce. The first cohort of apprentices from up and down the country including Newcastle United, Manchester United, Liverpool FC and other London clubs are part of the pilot cohort, with a planned role out across other sports and community organisations.

The club operates through Brentford FC Limited and the subsidiary Lionel Road Developments Limited (“LRD”). The club and LRD together with other (dormant) companies make up the “Group”. References to the club in this statement cover the Group. This statement is not made on behalf of the BFC CST which is a separate legal entity and the BFC CST is not subject to the reporting requirements of the Modern Slavery Act. However, the BFC CST is a key supplier to the club and is subject to compliance with key policies and risk assessment along with other suppliers.

The club operates in the UK and to the extent that has any overseas business that consists of very short trips abroad for training and friendly games and servicing fans based globally with retail and memberships. The club has a global profile through our participation in the Premier League. Apart from our primary business of competing in professional football competitions, and the broadcast opportunities which arise out of those, the club promotes third parties through sponsorship, advertising and partnerships, sells club-branded goods and services through its retail store and online channels, and operates an event and hospitality business for fans and corporate customers.

Our Commitment to Tackling Modern Slavery

We are committed to taking steps to ensure that modern slavery does not exist across the club’s operations or supply chains. This statement sets out the club’s top-level commitment to addressing the risk of modern slavery and is recognised as being part of the development of an overall approach to address modern slavery risk as an integral part of the overall objectives of the club.

Following the Home Office’s statutory guidance, we cover the following six areas below:

  1. Organisation structure and supply chains

  2. Policies in relation to slavery and human trafficking

  3. Due diligence processes

  4. Risk assessment and management

  5. Key performance indicators to measure effectiveness of steps being taken

  6. Training on modern slavery and trafficking

Organisational structure and supply chains

Board of Directors of Brentford FC Limited:

The Board of Directors of Brentford FC Limited is accountable to the shareholders, the Football Association, Premier League, fans, sponsors and its community for compliance with the club’s legal obligations. The Board delegates responsibility for the club’s operations to the club’s executive staff, led by the club’s Chief Executive Officer on the off-field side of the business, and the Director of Football for the on-field side.

In common with many other sports clubs, we have a relatively small full-time staff and then engage a large number of staff as employees, through agencies, or sub-contractors, to work on match days, in catering, stewarding and other match day roles. All of these roles are important to providing the best experience for our fans but the nature of those match day roles mean they are often staffed by young people, with comparatively fewer qualifications than full time staff and a significant proportion of them earn relatively low wages. We are an accredited London Living Wage Employer and we voluntarily agree to pay every member of staff over the age of 18 at least the London Living Wage – which is set in line with the cost of living and is significantly above the current national minimum wage. The club also imposes this obligation on key third party organisations who supply us with staff to work at our sites.

The club operates an academy and women’s teams (which include under 18s), which means we must consider the welfare of the children and young people in our care. Young people are also engaged in other areas of the club and young players play for the first team. The welfare of our youngest and most vulnerable people is therefore a high priority for all our staff. We employ a full-time specialist Operational Risk Director whose responsibilities include leading the Safeguarding team’s care of vulnerable people across the club. Consideration is given to the ongoing education and welfare of players in the academy, B team, women’s teams and First team to ensure the risk of them being exploited is minimised as far as possible.

Safeguarding is at the heart of everything we do, and we operate within the Football Association’s and Premier League’s safeguarding framework which include a requirement to submit to an annual external audit of the club’s safeguarding practices. Internally, safeguarding is presided over at the highest level. The club’s General Counsel and Board Director acts as the club’s senior safeguarding lead at the Board level, and he also chairs a bi-monthly Safeguarding Board, attended by senior representatives from across the club (and its associated Community Sports Trust).

Our supply chains include suppliers of goods and services which support our participation in football competitions, including the accompanying broadcast commitments, our commercial operations, including advertising partners and sponsors, our retail operations – in particular sports apparel, entertainment and events. Key suppliers identified as part of our risk assessment in 2023 were the club’s primary apparel, hospitality, food and beverage partners. All the foregoing have Modern Slavery statements on their websites where required and we make compliance a condition of our contractual relationship. As part of our relationships with those companies we have the ability to interrogate them about their procedures to ensure that we and they remain in compliance with our policies.

The club selects new suppliers against pre-agreed criteria to mitigate risks to the club. The club also has an onboarding process for new suppliers that ensures they meet the club’s minimum standards and includes due diligence checks to identify risks, including slavery and trafficking. We carry out periodic risk assessments to consider the areas of the business where modern slavery and exploitation may be a risk and give the most attention to these areas.

The club is committed to creating and ensuring a non-discriminatory working environment for our staff and non-discrimination policies apply to all employees. The club obtained the preliminary level of the Premier League’s Equality, Diversity & Inclusion Standard in 2023, and we obtained the intermediate level in early 2025.

Policies in relation to slavery and human trafficking

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].

Due diligence process

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.

Risk assessment and management

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.

Key performance indicators to measure effectiveness of steps being taken

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.

Training on modern slavery and trafficking

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

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