December 2025
Introduction
Norwich City Football Club (the “Club”) is committed to conducting its business in a morally principled manner. The Club is aware, however, that modern slavery can be found in all sectors. Therefore, the Club needs to be cognisant of this.
Section 54 of the Modern Slavery Act 2015 requires companies with a turnover over £36m to publish an annual slavery and human trafficking statement.
The Club is committed to addressing the risk of modern slavery across the Club’s group of companies and within our supply chains. This statement sets out the steps that we have taken to minimise, as far as possible, the risk of modern slavery taking place, as well as the steps which we propose to take to further mitigate against such risks.
What is modern slavery?
In this statement, where we say “modern slavery” we are referring to the illegal exploitation of people for personal or commercial gain, which can include forced labour, domestic servitude, human trafficking, sexual exploitation, criminal exploitation and organ harvesting.
We also recognise that modern slavery comprises the worst forms of exploitation, and seek to reduce the risk of poor working practices such as unsafe working conditions, discrimination, excessive working hours and late or below minimum payment of wages.
Organisational structure
The Club is a professional football club playing in the EFL Championship. The Club has an international presence, both in terms of its supply chains and its supporter reach.
Norwich City Football Club PLC is the company that operates the Club, and also owns 75% of Norwich City FC Regional Development Programme Ltd (together, the “Group”). Carrow Road Events is a brand name used by Norwich City Football Club PLC. All references in this statement to “we” or “our” is to the Group.
The Club has a broad range of domestic and international commercial partners, sponsors and suppliers. The Club’s operations are primarily conducted in the UK. We employ approximately 215 members of full-time staff, 80 members of part-time staff, and also have approximately 1,000 casual workers who predominantly perform match day and events roles. The significant majority of our staff are employed and based in the UK.
Our General Counsel has primary and day-to-day accountability for implementing our Modern Slavery Policy. This includes monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery, or delegating such activities to competent supporting functions as deemed appropriate.
The Club undertakes a governance briefing for senior management every three months, and one of the topics covered in such briefings is modern slavery. This provides an update on latest developments in this area as well as educating senior managers on signs that may indicate that modern slavery is taking place. When drafting our annual modern slavery statement, we gather information from our legal, retail, catering, HR and finance teams.
Our supply chains
Our supply chains include suppliers of IT and other office equipment, food and beverage suppliers, retail suppliers and commercial suppliers. Our supply chain features predominantly UK businesses, though we also have a number of business relationships with a range of organisations around the world. We have over 800 reoccurring suppliers in our supply chain, and maintain records of all of our suppliers.
The Club acknowledges, like most companies, that we have visibility gaps beyond our tier 1 suppliers, which is why we seek to partner with suppliers that share our values. We expect our supply chain to operate fair and equitable practices, whereby modern slavery and related poor labour practices are not tolerated. We are committed to taking steps to ensure that modern slavery does not occur across the Club’s operations or supply chains. This statement sets out the Club’s commitment to addressing the risk of modern slavery and is recognised as being part of the development of an overall strategy to address modern slavery risk as an integral part of the overall objectives of the Club.
Our policies and processes
We are committed to ensuring, as far as possible, that there is no modern slavery in our supply chains or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery taking place in our supply chains.
The Club requires suppliers to sign up to the Club’s Modern Slavery Policy by including a clause in each agreement it enters into with a supplier. The only instance in which the Club will accept the supplier not signing up to this clause, is where they include wording into the contract which is equal to or more stringent than the Club’s policy. Potential consequences for breaches are also made clear in supplier contracts, and appropriate corrective action will be determined for these situations.
Should any potential non-compliance be reported to us, we will work to remedy any areas in which we or our suppliers do not meet the appropriate standards that we expect to work to. We may cease trading with partners who do not continue to meet our requirements or breach relevant regulations. There are no current issues of non-compliance with modern slavery laws that we have been made aware of.
The Club has in place safer recruitment processes which are transparent and reviewed regularly. They include robust procedures for vetting new employees, which ensures they are able to confirm their identities and qualifications, and they are paid directly into an appropriate, personal bank account in their name only.
The Club has a dedicated safer sport team that works across the Group to protect the welfare of all children and adults at risk that come into contact with the Group. Safer sport specific policies and embedded referral processes are in place, which are published on the safer sport page of the Club’s website. All reported modern slavery concerns will be reported to the Safer Sport team.
Our Head of Safer Sport currently chairs the Norfolk Anti-Slavery Business Group. This group meets quarterly to discuss the nature and scale of modern slavery in Norfolk and consider how best local business can address the issue. The Club has been delighted to host the group at Carrow Road this year, and provided a forum for local stakeholders to share their activities to raise awareness of modern slavery during Anti-Slavery Week in October 2025.
The Club also has a Speak Up Policy, otherwise known as a whistleblowing policy, which details the procedures for how to report a matter to the Club. This is promoted both internally and to external parties that we interact with. No concerns regarding modern slavery or human trafficking have been reported through our Speak Up Policy.
The Club also operates a Grievance Procedure and a Harassment Policy, which enables our employees to escalate concerns regarding their treatment at work.
Risk assessment
The Club recognises that we have a number of potential risk areas for modern slavery, including but not limited to the risk of outsourced labour and sourcing products from high-risk countries, such as China, as outlined in the Global Slavery Index.
The Club will further refine our risk assessment model to be used, initially, in respect of the Club’s most significant suppliers by spend and sector. Suppliers deemed to be highest risk will be asked to complete a further assessment to quality assure the commitments given by these suppliers. The data received will be analysed and will guide our risk management actions going forward.
Due diligence
In relation to all of our supply chains, we ensure that the parties we are contracting with are aware of and agree to our Modern Slavery Policy and our commitments to reducing the risk of modern slavery taking place.
We do this in a number of ways, including requiring suppliers to agree to our supplier terms and conditions or by adding our anti-modern slavery requirements into their terms and conditions. This makes it a condition that they agree to our practices, which are targeted at removing the risk of modern slavery from our supply chains.
As part of our initiative to identify and mitigate this risk, we include anti-modern slavery provisions within our commercial contracts to ensure the parties we work with understand our commitment to, and comply with the terms of, our Policy.
We also speak to companies in our supply chains regularly about their processes and how they source labour and materials, as well as asking to see their anti-modern slavery commitments.
Future actions
We continue to review our suppliers and their practices to mitigate the risk of modern slavery within our business and supply chains, which includes (but is not limited to) visits to our overseas suppliers, such as our kit manufacturer, to inspect working practices first-hand.
Our continued strategy also includes plans to develop a refined and updated supplier due diligence questionnaire for existing and prospective suppliers and partners. This will ensure that we are asking the appropriate questions of suppliers, enabling an assessment of their approach to addressing modern slavery risks. This will form a key part of our supplier selection and management process.
We are also highlighting the risks of modern slavery as part of our induction process and reviewing our in-house training provision, to ensure that we can deliver targeted and relevant training to staff on a regular basis.
Training
To ensure a high level of understanding and awareness of the risks of modern slavery in our supply chains and our business, we will provide or procure training to our relevant staff over and above the introductory level training mentioned above. We may also work with external organisations who specialise in modern slavery awareness raising to arrange speakers and external training to the full staffing cohort.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Norwich City Football Club PLC’s slavery and human trafficking statement for the financial reporting period ending 30 June 2025. This statement received Board approval on 3 December 2025.
Zoe Webber, Executive Director
On behalf of the Board of Directors of Norwich City Football Club PLC
3 December 2025