SEXUAL HARASSMENT & RESPECT AT WORK POLICY

We Make Footballers ("WMF") is committed to providing working and coaching environments in which everyone is treated with dignity and respect.

Sexual harassment, sex-based harassment, sexually inappropriate behaviour, victimisation and retaliation are not tolerated in connection with WMF activities.

WMF operates internationally through independently owned and operated franchise businesses alongside central WMF operations. Each franchise is responsible for the individuals it employs or engages in connection with its academy, which may include employees, workers, coaches, independent contractors, casual personnel, agency personnel and volunteers.

This policy sets the minimum WMF standard. Each WMF entity and franchise must also comply with the laws that apply in the country, state, territory or locality in which it operates. Where local law sets a higher or more specific standard, that requirement applies.

Nothing in this policy changes an individual's legal employment status or creates an employment relationship between WMF Head Office and an individual employed or engaged by an independently owned franchise.

Who This Policy Covers

The WMF standard applies to work-related conduct involving people working in or connected with WMF-branded operations, including franchise owners, employees, workers, coaches, independent contractors, agency personnel, volunteers, parents and carers, spectators, school and venue personnel, suppliers and other third parties.

It can apply to conduct occurring during WMF sessions, camps, leagues, tournaments, events, meetings, training, work-related travel and social events.

It also applies to work-related communication through email, telephone, messaging applications, staff groups and social media, as well as interactions with parents, carers, schools, venues and other organisations.

Our Global Standard

Every WMF operation is expected to:

• maintain a working and coaching environment where sexual harassment is not tolerated;
• communicate clear standards of behaviour;
• provide an accessible way for concerns to be raised;
• take concerns seriously and respond appropriately;
• take reasonable preventative measures appropriate to its circumstances;
• protect people who raise genuine concerns from victimisation or retaliation;
• address inappropriate behaviour involving third parties where reasonably possible;
• maintain appropriate records; and
• comply with all applicable local laws.

A written policy alone is not enough. These standards must be implemented in practice.

Franchise Responsibility

Each WMF academy is independently owned and operated.

The local franchise owner is responsible for implementing the applicable country requirements within their business and complying with the legal obligations that apply to the people they employ or engage.

WMF Head Office sets network standards and may provide policies, guidance, training materials and escalation support. This does not remove the franchise owner's responsibility for operating their own business lawfully.

Safeguarding

This policy operates alongside WMF's Safeguarding Children Policy and Procedures.

Where conduct involves, may involve or may affect a child or young person, the applicable safeguarding policy and reporting procedures must also be followed.

A sexual-harassment process does not replace any child-protection or mandatory-reporting obligation. Where both policies apply, both may need to be followed.

United Kingdom

Applies to WMF operations in England, Wales and Scotland.

Employment and equality law in Northern Ireland is different. If WMF operates in Northern Ireland, the applicable Northern Ireland requirements must be reviewed separately.

Purpose

WMF UK is committed to preventing sexual harassment and maintaining respectful working and coaching environments.

This standard applies across WMF UK central operations and independently owned and operated UK franchises.

It applies to people working in or connected with those operations, including employees, workers, franchise owners, coaches, independent contractors, agency personnel, casual personnel and volunteers.

The legal rights and obligations applying to a particular person may depend on their employment status and their relationship with the relevant business.

UK Legal Framework

Relevant UK legislation includes the Equality Act 2010, the Worker Protection (Amendment of Equality Act 2010) Act 2023, the Employment Rights Act 1996 and the Employment Rights Act 2025.

Employers are currently required to take reasonable steps to prevent sexual harassment of their employees.

From 30 October 2026, this duty strengthens so that employers must take all reasonable steps to prevent sexual harassment of their employees. Additional protections concerning harassment of employees by third parties also apply from that date.

The new third-party harassment protections extend beyond sexual harassment. Harassment connected with other protected characteristics should also be considered under WMF's Equality & Diversity and other applicable anti-harassment standards.

Since 6 April 2026, sexual harassment has also been expressly included among the types of wrongdoing that may form the subject of a protected whistleblowing disclosure.

A sexual-harassment complaint does not automatically qualify as a protected whistleblowing disclosure. The statutory whistleblowing requirements must still be satisfied.

What Sexual Harassment Means

Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.

Examples can include:

• sexual comments, jokes or "banter";
• unwanted touching or physical contact;
• sexual gestures;
• displaying or sharing sexual images or material;
• sexual propositions or advances;
• requests for sexual favours;
• comments about someone's body, appearance or sex life;
• spreading sexual rumours;
• sexually explicit messages;
• inappropriate sexual content in work-related groups; and
• persistent unwanted sexual attention.

Sexual harassment does not need to happen repeatedly before it can be serious.

Harassment related to sex, and detrimental treatment connected with rejecting or reporting sexual harassment, may also be unlawful.

Preventing Sexual Harassment

Franchise owners must consider where sexual harassment risks could reasonably arise within their academy.

Relevant risks may include interactions with parents and carers, spectators, schools, venue personnel, contractors, lone working, staff messaging groups, camps, tournaments, travel, younger workers or coaches, power imbalances and previous complaints or concerns.

Appropriate preventative measures should reflect the risks identified and may include clear behavioural expectations, training, supervision, reporting channels and procedures for working at third-party venues.

Risk controls should be reviewed when circumstances change or when an incident indicates that existing controls may not be sufficient.

Third-Party Harassment

WMF personnel regularly interact with people outside their own organisation, including parents, carers, spectators, school personnel, venue staff, customers, suppliers and contractors.

Franchise owners should consider these interactions when assessing harassment risks.

Where inappropriate third-party behaviour occurs, appropriate action may include addressing the behaviour, restricting or removing someone from a session, notifying a venue or school, changing working arrangements, supporting the person affected or reviewing whether a venue or commercial relationship should continue.

Coaches and Contractors

Each WMF franchise is responsible for the people it employs or engages.

WMF does not assume that every coach is an employee.

Employees, workers, coaches, contractors and volunteers working in WMF-branded activities are expected to comply with this policy and the standards of behaviour it establishes.

Where a person is engaged as an independent contractor, this policy does not convert that relationship into employment. Contractor status also does not remove any legal protections that may apply to the particular working relationship.

Reporting a Concern

Concerns should normally be raised with the local Franchise Owner or another designated local manager.

Where the allegation concerns the Franchise Owner, the local route is inappropriate, the matter is not being handled appropriately, or there is a serious safeguarding or WMF compliance concern, it may be escalated to:

WMF Head Office
info@wemakefootballers.com

WMF should ensure that access to reports of this nature is appropriately controlled and that concerns are routed to the correct person.

Nothing in this process prevents someone from exercising their statutory rights or contacting an appropriate external authority.

Whistleblowing

Some reports concerning sexual harassment may also amount to whistleblowing.

A disclosure concerning sexual harassment may qualify for statutory whistleblowing protection where the legal requirements for a protected disclosure are satisfied.

The sexual-harassment and whistleblowing procedures should therefore cross-reference one another where appropriate.

What Happens When a Concern Is Raised

Reports should be taken seriously and handled without unreasonable delay.

The appropriate process will depend on the nature, seriousness and complexity of the concern.

The person responsible for handling the matter should consider immediate safety or safeguarding needs, determine who should investigate, gather relevant information, allow the people involved an appropriate opportunity to respond, maintain appropriate confidentiality and determine whether external reporting is necessary.

Possible outcomes can include changes to working arrangements, further guidance or training, disciplinary action where an employment process applies, removal from coaching duties, termination or non-renewal of a contractor engagement, removal of a parent or spectator from an activity, action involving a venue or partner, safeguarding action or referral to an appropriate authority.

Victimisation and Retaliation

WMF does not tolerate victimisation or retaliation against someone because they raised a genuine concern, supported another person's complaint, provided evidence, participated honestly in an investigation or exercised a legal right.

Protection from inappropriate retaliation does not depend on a complaint ultimately being upheld.

Knowingly false or malicious allegations may be dealt with separately.

Confidentiality and Data Protection

Sexual-harassment concerns can involve sensitive personal information.

The franchise or WMF entity handling the matter must manage information in accordance with applicable data-protection requirements.

Information should only be shared where reasonably necessary to protect those involved, investigate or respond to the concern, comply with legal or safeguarding obligations or obtain appropriate professional advice.

Absolute confidentiality cannot be promised where disclosure is necessary to investigate a concern, protect another person or comply with the law.

Training and Communication

Franchise owners should ensure that people working within their academy understand the expected standards of behaviour, how to recognise inappropriate conduct, how to report concerns and the prohibition on victimisation.

Training and communication should be appropriate to the nature and risks of the operation and must meet any applicable legal requirements.

Schools and Venues

Schools, venues and partner organisations may request evidence of WMF's sexual-harassment arrangements as part of their own contractor or facility procedures.

Where requested, a franchise may provide the current UK version of this policy together with relevant safeguarding documentation.

This policy does not state that a Sexual Harassment Policy is a nationally mandated statutory item on every school's Single Central Record. Individual schools or trusts may choose to request and record additional compliance information under their own procedures.

Safeguarding in the UK

Where conduct involves a person under 18 or raises a child-welfare concern, the WMF UK Safeguarding Children Policy must also be followed.

Any immediate safeguarding action must not be delayed while an employment or harassment process is considered.

United States

Purpose

WMF USA prohibits sexual harassment and retaliation connected with WMF-branded activities.

This section establishes a national WMF minimum standard.

Employment and harassment laws in the United States vary significantly between federal, state and local jurisdictions. Each independently owned franchise must comply with the requirements that apply where it operates.

Federal Framework

At federal level, sexual harassment can constitute unlawful sex discrimination under Title VII of the Civil Rights Act of 1964.

Title VII generally applies to covered employers with 15 or more employees.

Whether an individual is considered an employee for Title VII purposes depends on the applicable legal test. A genuine independent contractor is not automatically treated as an employee under Title VII.

Employers can, however, have responsibilities where their employees are harassed by non-employees such as customers or independent contractors and the employer knew or should have known about the conduct but failed to take appropriate corrective action.

State and Local Requirements

State and local law may provide broader protections than federal law.

Depending on the jurisdiction, these laws may cover smaller employers, protect contractors, require written policies, prescribe complaint procedures, require notices, mandate training or impose additional recordkeeping requirements.

Every WMF franchise is responsible for identifying and complying with the requirements applicable to its location.

Where state or local law provides greater protection than this policy, that higher standard applies.

New York

New York requires all employers to adopt a sexual-harassment prevention policy that meets state minimum standards.

Employees must receive qualifying interactive sexual-harassment prevention training at least annually.

WMF franchises operating in New York must comply with those requirements in addition to this WMF policy.

California

California protects employees, applicants, unpaid interns, volunteers and contractors from workplace harassment.

Employers with five or more employees must provide qualifying sexual-harassment prevention training to supervisory and nonsupervisory employees.

The required training is generally repeated every two years.

WMF franchises operating in California must comply with those requirements in addition to this WMF policy.

These examples do not represent a complete list of state or local requirements.

Prohibited Conduct

WMF prohibits sexual harassment in connection with WMF-branded activities.

Examples may include:

• unwanted sexual advances;
• requests for sexual favours;
• unwanted touching;
• sexual jokes or comments;
• sexual gestures;
• sexual images or messages;
• comments about someone's body or private life;
• persistent unwanted sexual attention;
• conditioning opportunities on sexual conduct; and
• retaliation following rejection or reporting of sexual behaviour.

Franchise Responsibility

Each WMF USA academy is independently owned and operated.

The franchise owner is responsible for complying with applicable federal, state and local law, maintaining legally required policies and notices, providing legally required training, establishing reporting channels, responding appropriately to concerns and maintaining required records.

WMF's policy does not determine whether an individual is legally an employee or contractor.

Contractors

Coaches and other personnel may be engaged as independent contractors.

They remain subject to WMF's behavioural standards.

Franchise owners should not assume that describing someone as an independent contractor automatically removes all harassment-related obligations. The actual working relationship and applicable federal, state and local law must be considered.

Third Parties

Sexual harassment connected with WMF activities may involve parents, guardians, spectators, venue staff, school personnel, suppliers or other contractors.

Where inappropriate conduct is known and the franchise has the ability to take corrective action, the franchise should respond promptly and appropriately.

Reporting and Response

Concerns should normally be raised with the local Franchise Owner or another reporting contact established by the franchise.

Where the concern involves the Franchise Owner, is not being handled appropriately or creates a serious safeguarding or WMF compliance concern, it may be escalated to:

WMF Head Office
info@wemakefootballers.com

Depending on the circumstances, action can include immediate safety measures, investigation, changes to working arrangements, employment action where applicable, removal from coaching duties, termination or non-renewal of an engagement, removal of a third party, safeguarding action or referral to an appropriate authority.

Nothing in this policy prevents anyone from contacting the Equal Employment Opportunity Commission, an applicable state or local civil-rights agency, law enforcement or another competent authority.

Retaliation

WMF prohibits retaliation against a person because they made a good-faith harassment report, supported another person's report, participated honestly in an investigation or exercised rights under applicable law.

Safeguarding in the United States

Where conduct involves or may affect a person under 18, the WMF USA Safeguarding Children Policy and applicable child-protection reporting requirements must also be followed.

Internal reporting to the franchise or WMF does not replace any legally required report to authorities.

United Arab Emirates

Purpose

WMF is committed to maintaining safe and respectful working and coaching environments throughout its UAE operations.

This section establishes the WMF standard for sexual harassment within operations subject to the UAE federal private-sector employment framework.

UAE Legal Framework

Under Federal Decree-Law No. 33 of 2021 Regarding the Regulation of Employment Relationships, as amended, employers are required to provide workers with a safe and appropriate working environment.

Article 14 prohibits sexual harassment, bullying and verbal, physical or psychological violence against workers by employers, superiors, colleagues or other people working with them.

This statutory framework applies to workers within employment relationships governed by the Federal Labour Law.

WMF does not state that every independent contractor automatically receives identical statutory employment-law protection.

WMF nevertheless applies the behavioural standards in this policy to individuals engaged in WMF-branded activities.

DIFC and ADGM

Certain UAE financial free zones operate under separate employment regimes.

Abu Dhabi Global Market and Dubai International Financial Centre each have their own employment frameworks.

Where a WMF operation or employment relationship falls within one of those jurisdictions, the applicable local employment requirements must be reviewed separately.

Prohibited Conduct

WMF prohibits sexual harassment and sexually inappropriate conduct.

Examples include:

• unwanted sexual comments;
• sexual jokes or gestures;
• unwanted touching;
• sexual propositions;
• requests for sexual favours;
• sexual messages or content;
• sexual comments about someone's appearance or private life;
• sexual intimidation or pressure; and
• retaliation against someone raising a genuine concern.

Serious behaviour may also constitute a criminal offence under UAE law.

Franchisees and Contractors

Each WMF academy is independently owned and operated.

The franchise owner is responsible for complying with legal requirements applying to its own business and workforce.

Where a coach or other person is engaged as a contractor, this policy still applies as a WMF behavioural standard. It does not convert that person into an employee or determine their statutory employment status.

Third Parties

WMF personnel may interact with parents, spectators, schools, venue staff, suppliers, contractors and other organisations.

Inappropriate sexual conduct involving third parties should be addressed promptly and proportionately.

Depending on the circumstances, this can include removing someone from an activity, informing venue management, changing working arrangements, reviewing the commercial relationship or contacting competent authorities.

Reporting and Response

Concerns should normally be raised with the local Franchise Owner or designated manager.

Where the concern involves the Franchise Owner or is not being handled appropriately locally, it may be escalated to:

WMF Head Office
info@wemakefootballers.com

Reports should be handled seriously and without unreasonable delay.

Appropriate action may include safety measures, investigation, changes to working arrangements, employment action where applicable, removal from coaching duties, termination or non-renewal of a contractor engagement, removal of a third party, safeguarding action or referral to competent UAE authorities.

WMF prohibits retaliation against anyone raising or supporting a genuine concern.

Safeguarding in the UAE

Where conduct involves or may affect someone under 18, the WMF UAE Safeguarding Children Policy must also be followed.

Nothing in this policy delays or replaces any external reporting obligation imposed by UAE child-protection or criminal law.

Australia

Purpose

WMF Australia is committed to providing safe, respectful and inclusive working and coaching environments.

This section establishes the WMF standard and reflects the Australian federal workplace sexual-harassment framework.

Applicable state and territory requirements must also be followed.

Australian Legal Framework

Relevant federal legislation includes the Sex Discrimination Act 1984 and the Fair Work Act 2009.

Australian law prohibits sexual harassment connected with work.

The Sex Discrimination Act also creates a positive duty requiring employers and persons conducting a business or undertaking to take reasonable and proportionate measures to eliminate, as far as possible, sex discrimination, sexual harassment, sex-based harassment, hostile workplace environments on the ground of sex and related victimisation.

This is a preventative duty. Businesses should not wait until a complaint is made before considering the risk.

Contractors and Other Workers

Australian workplace sexual-harassment protections extend beyond traditional employees.

Depending on the applicable law and circumstances, workers can include employees, contractors, subcontractors, employees of contractors, labour-hire workers, apprentices, trainees, interns, work-experience students and volunteers.

A person or business engaging an independent contractor may also have responsibilities as a principal.

Franchisees should therefore include contractors within their harassment-prevention arrangements where applicable.

What Sexual Harassment Means

Sexual harassment includes unwelcome conduct of a sexual nature in circumstances where a reasonable person would anticipate that the person affected might be offended, humiliated or intimidated.

Examples can include unwanted touching, sexual jokes or comments, sexual gestures, intrusive sexual questions, sexual propositions, requests for sexual favours, sexually explicit messages or images and unwanted sexual attention.

Conduct can occur in person or electronically.

Positive Duty and Prevention

Each franchise should consider what reasonable and proportionate preventative measures are appropriate to its circumstances.

Relevant considerations can include the size and structure of the business, workforce profile, use of young or casual workers, contractor arrangements, parent and spectator interaction, schools and venues, messaging groups, lone working, camps, travel and previous incidents.

Prevention measures may include clear leadership expectations, policies, consultation, risk assessments, appropriate training, reporting channels, appropriate responses, monitoring and periodic review.

Third-Party Conduct

Australian preventative duties can extend to relevant unlawful conduct involving third parties.

Third parties in a WMF environment may include parents, customers, spectators, schools, venue personnel, suppliers, visitors and other organisations.

Franchise owners should include foreseeable third-party risks within their prevention arrangements.

Franchise Responsibilities

Each WMF Australia academy is independently owned and operated.

The franchise owner is responsible for meeting applicable federal, state and territory obligations and for implementing appropriate prevention and reporting procedures within their own operation.

Reporting and Response

Concerns should normally be raised with the local Franchise Owner or another designated reporting contact.

Where the concern involves the Franchise Owner, is not being handled appropriately or raises a serious safeguarding or WMF compliance issue, it may be escalated to:

WMF Head Office
info@wemakefootballers.com

Depending on the circumstances, a person may also seek assistance through the Fair Work Commission, Fair Work Ombudsman, Australian Human Rights Commission, an applicable state or territory authority or police.

Possible responses can include immediate safety measures, investigation, changes to working arrangements, employment action where applicable, removal from coaching duties, termination or non-renewal of a contractor engagement, removal of a third party, action involving a venue or school, safeguarding action or external referral.

Victimisation

Victimisation connected with raising or supporting a sexual-harassment concern is prohibited.

Franchise owners should take appropriate steps to prevent retaliatory treatment following a complaint.

Safeguarding in Australia

Where conduct involves or may affect someone under 18, the WMF Australia Safeguarding Children Policy and applicable state or territory reporting obligations must also be followed.

How This Policy Works With Other WMF Policies

This policy should be read alongside the relevant WMF policies and procedures.

• Safeguarding Children applies where children or young people are involved.
• Equality & Diversity addresses discrimination and harassment connected with other protected characteristics.
• Whistleblowing may apply where a report satisfies the requirements for a protected disclosure.
• Codes of Conduct establish expected behaviour for coaches, personnel, parents and others connected with WMF.
• Privacy and Data Protection requirements apply to information collected during complaints and investigations.

Publication and Review

The current policy should be available through the WMF Policies page under:

Sexual Harassment & Respect at Work

The applicable country section should then be clearly identified as:

• United Kingdom
• United States
• United Arab Emirates
• Australia

The policy should be reviewed whenever there is a material change to applicable law, WMF's operating model, safeguarding requirements or the risks identified within WMF operations.