Sanctions and Banning Policy

Tottenham Hotspur Sanctions and Banning Policy

PART 1: DEFINITIONS

In this Policy:

"Brisbane Road" means Brisbane Road, Leyton, London, United Kingdom, E10 5NE;

"Club" means Tottenham Hotspur Limited and all group entities (including but not limited to Tottenham Hotspur Football & Athletic Co. Ltd, Tottenham Hotspur Women Football Club Limited and Tottenham Hotspur Football Co Limited);

"Event" means any event or participation in a visitor attraction, excluding Matches, held at any of the Premises (including but not limited to NFL matches, karting and concerts);

"Face Value" means the price at which Match tickets can be acquired through the Club’s official channels including but not limited to Club’s authorised resellers;

"Malicious Communications" means conduct which intends to cause, or at least is foreseeable that it will cause, serious distress or anxiety to the target and/or recipient (including but not limited to any social media channel or platform, telephone calls and emails);

"Match" means all Club matches;

"Member" means any Club season ticket holder, One Hotspur Member, One Hotspur Connect Member or any holder of other membership tiers;

"Policy" means the Club’s Sanctions and Banning Policy;

"Premises" means the Stadium and all other stadia (including but not limited to Brisbane Road), land and buildings (including but not limited to the karting centre located at the Stadium), including the footprint of such premises, owned and/or controlled by the Club which is being used for the holding of a Match or an Event;

"Sanctioning Officer" means an appropriately trained administrator who determines the appropriate sanction following the conclusion of an investigation that this Policy has been breached by a Member or any other individual;

"Sexual Misconduct" means any conduct of sexual nature that is non-consensual or has the purpose or effect of threatening, intimidating, undermining, humiliating or coercing a person.

"Sporting Events" means all sporting events held at any of the Premises (including but not limited to NFL matches and rugby matches); and

"Stadium" means the Tottenham Hotspur Stadium located at 782 High Road, Tottenham, London N17 0AP.

In this Policy, the use of the singular includes the plural and vice versa.

PART 2: INTRODUCTION

Policy Statement

This Policy applies to any Member or other individual who commits a behavioural or ticketing offence as set out in Part 3, at any Match and/or Event at/on/in relation to any of the Premises, or otherwise commits an offence in connection with the Club. This includes offences under the Football (Offences) Act 1991.

This Policy is compliant with the requirements and principles of the Equality Act 2010 and will be applied accordingly.

This Policy complements and does not override the Stadium’s Ground Regulations, the men's and women's Membership and Ticketing Terms and Conditions, the Ticket Touting Policy Statement and any other regulations or policy specific to each of the Premises.

This Policy supersedes any and all other policies’ application of sanctions, as of the date of publication, July 2024.

Purpose

The purpose of this Policy is to ensure the safety of and enhance the experience of all Members, Event attendees and visitors to any of the Premises, regardless of the capacity they are attending in.

The framework of offences and corresponding sanctions alongside the appeals process outlined in this Policy are designed to give all Members, Event attendees and visitors to any of the Premises clarity on how the Club will deal with transgressions.

PART 3: SANCTIONS

Sanction Conditions

Any period of ejection, suspension, ban or other sanction will apply to all Matches, Events and Premises and the right to access or purchase tickets, memberships or experiences.

The granting of any refunds for periods of ejection, suspension, ban or other sanction remains at the sole discretion of the Club.

In circumstances where an ejection, suspension, ban or other sanction is overturned by the Appeal Panel, the Club will refund the cost of any Matches and/or Events paid for and missed as a result of such ejection, suspension, ban or other sanction.

The Club does not assume any liability by virtue of this Policy or otherwise for any other direct, indirect or consequential losses arising in connection with the ejection, suspension, ban or other sanction.

Full details of any sanction and the process by which they are applied or appealed will be provided in writing.

Types of Offences and Sanctions

The following breakdowns are a guide for how the Club will treat behavioural and ticketing offences at Matches and Events, recognising that they are distinct and require separate sanctions.

Offences will be reported to the police where appropriate. In the event of a police investigation, the Club's own investigation will be suspended until the police investigation and any proceedings which might follow have concluded.

The Club will deal with each case on an individual basis and reserves the right to use its discretion within the recommended sanction bands provided below. In cases where proven offences involve aggravating features such as violent, threatening or discriminatory behaviour or where the Club’s safety operation is impaired, the Club reserves the right to apply a greater sanction than outlined below.

The Club also reserves the right to extend or reduce the recommended length of time of sanctions if the original sanction falls within the football off-season period or to reflect the forthcoming Match fixture schedule at the time of sanction. This is to ensure that a ban is proportionate to the incident in question.

Where offences are committed by minors, the Club reserves the right to extend the ban to their accompanying parent(s) or guardian(s). This includes, but is not limited to, cases involving entering the field of play during Matches and Sporting Events and the possession and/or use of pyrotechnics, which are defined as handheld flares, fireworks and smoke bombs.

I. Matches: Behavioural Sanctions

Any Member or other individual who commits a behavioural offence at any Match, at/on/in relation to any of the Premises, or otherwise commits an offence in connection with the Club will be subject to the following recommended sanctions:

Level	Offence	Recommended Sanction
1	Smoking (including e-cigarettes)	Written warning
	Persistent standing in the Stadium’s unlicensed standing areas
	Refusal to follow stewards’ reasonable instructions
	Drinking alcohol in view of the pitch during Matches

2	Possession of any prohibited items listed in Ground Regulations (increased sanction possible depending on item)	Up to a four (4) Match/Event ban or two (2) month ban, whichever is greater
	Misuse of Match tickets (e.g. in wrong area, using concession ticket)
	Repetition of Level 1 Offences
3	Damaging property or facilities	Up to a ten (10) Match/Event ban or five (5) month ban, whichever is greater
	Attempting to gain access without a valid ticket
	Attending any Match while subject to a suspension as a result of an offence under the terms of this Policy
	Repetition of Level 1-2 Offences
4	Violent or aggressive behaviour towards other Members, visitors to any of the Premises, staff or police	Up to an indefinite ban
	Any other illegal activity
	Possession of pyrotechnics
	Entering the field of play
	Throwing missiles
	Possession of an illegal substance
	Assault
	Sexual Misconduct
	Use of discriminatory language
	Sending and/or relaying Malicious Communications targeted/directed at players, Club staff and/or individuals connected to the club.
	Repetition of Level 1-3 Offences

Where identifiable, Members and other individuals using discriminatory and/or threatening or abusive language towards Club staff and/or players via social media, telephone calls or emails will be treated as if the offence has been committed at any of the Premises. The Club reserves the right to use its discretion as to what constitutes discriminatory and/or threatening or abusive language and such offence may incur a sanction up to and including an indefinite ban.

If requested for away Match fixtures, and where the presence of a banned Member or individual would pose a risk to others (in cases where offences have been violent, discriminatory, or threatening in nature), the Club will provide details of Members and individuals sanctioned with a ban to relevant opposition clubs. Information (including name, address, date of birth and photo where applicable) will be supplied in line with information sharing agreements and approved by the Club’s Data Protection Officer to ensure compliance with relevant legislation.

The Club is registered with the Information Commissioner’s Office and manages personal data in accordance with its Data Protection Policy.

The Club may impose sanctions in the event of a Member or an individual breaching regulations at another stadium during an away Match fixture, following an investigation consistent with our Policy for home Matches.

II. Matches: Ticketing Sanctions

Any Member or other individual who commits a ticketing offence in connection with any Match will be subject to the following recommended sanctions:

Offence	Recommended Sanction
Selling or attempting to sell home Match tickets for equal or less than Face Value	Written warning
Selling or attempting to sell home Match tickets for more than Face Value	Indefinite ban
Selling or attempting to sell home Match tickets to visiting football supporters	Indefinite ban
Selling or attempting to sell away Match tickets for equal or less than Face Value	Written warning and removal of fifty percent (50%) of ticketing points
Selling or attempting to sell away Match tickets for more than Face Value	Indefinite ban and removal of all ticketing points

Members and other individuals are reminded that home men’s Match tickets can be shared and sold officially by using the Ticket Share and Ticket Exchange platforms respectively. Notwithstanding this, if the home or away Match tickets are transferred outside the Club’s official channels, the obligations under this Policy continue applying to the original ticket holder unless (i) the original ticket holder discloses to the Club the identity and contact details of the transferee; and (ii) the Club is able to confirm that the identity is correct and matches the transferee. All Match tickets are prohibited from being sold via third parties. All tickets for away Matches cannot be resold or transferred under any circumstances.

Any individual who is a Platinum Season-Ticket Holder and commits a ticketing offence in connection with any Away Match will have their Platinum Membership revoked, in addition to the above Away Match sanctions.

The Club reserves the right to take action, including but not limited to precautionary action, against any Members or other individuals who are reasonably believed by the Club to be linked to anyone found to have sold Match tickets unofficially or in contravention of the Club's Ticket and Membership Terms and Conditions and Ticket Touting Policy Statement. This can be a link via previous purchase history, recorded methods of payment or by postal and/or email address.

III. Events: Behavioural Sanctions

Any Member or other individual who commits a behavioural offence at any Event, at/on/in relation to any of the Premises will be subject to the following recommended sanctions:

Level	Offence	Recommended Sanction
1	Smoking (including e-cigarettes)	Written warning
	Refusal to follow stewards' reasonable instructions
2	Possession of any prohibited items listed in Ground Regulations (increased sanction possible depending on item)	Up to a four (4) Match/Event ban or two (2) month ban, whichever is greater
	Misuse of Event tickets (e.g. in wrong area, using concession ticket)
	Repetition of Level 1 Offences
3	Damaging property or facilities	Up to a ten (10) Match/Event ban or five (5) month ban, whichever is greater
	Attempting to gain access without a valid ticket
	Attending any Event while subject to a suspension as a result of an offence under the terms of this Policy
	Repetition of Level 1-2 Offences

4	Violent or aggressive behaviour towards other Event attendees, visitors to any of the Premises, staff or police	Up to an indefinite ban
	Any other illegal activity
	Possession of pyrotechnics
	Entering any part of the Stadium not authorised to enter, including but not limited to the field of play during Sporting Events
	Throwing missiles
	Possession of an illegal substance
	Assault
	Sexual Misconduct
	Use of discriminatory language
	Sending and/or relaying Malicious Communications targeted/directed at players, Club staff and/or artists and/or individuals connected to the Club or Event.
	Repetition of Level 1-3 Offences

Sanction Process

During the period of (i) any police investigation into an alleged offence under this Policy, up to the conclusion of that investigation and any subsequent proceedings; and (ii) any subsequent investigation by the Club, the Member’s or individual’s account and right to attend all Matches, Events and Premises and the right to access or purchase tickets, memberships or experiences will be suspended.

Following the conclusion of any subsequent investigation by the Club into any alleged offence and any subsequent proceedings, whether resulting in an ejection or not, (which will draw on a range of evidence sources, including but not limited to, steward incident reports, witness statements, Control Room radio logs and CCTV footage, and other video/audio recordings) the Member or individual in question will receive written notice of the sanction to be applied with a summary of supporting evidence and rationale (a "Sanction Notice"). The Club will send the Sanction Notice to the Member’s or individual’s email address or postal address on file.

PART 4: APPEALS

A sanction can be appealed by submitting grounds for the appeal (together with any supporting evidence) in writing to appeals@tottenhamhotspur.com within fifteen (15) calendar days of the Club sending the Sanction Notice. There shall be no obligation to consider any grounds for appeal received after this period has elapsed.

Level 1 offences cannot be appealed. Level 2 offences can only be appealed in writing following the procedure outlined below in the “Written Appeal” section. There is no right to appeal sanctions comprised of written warnings other than on the grounds of mistaken identity.

Appeals of Level 3 and Level 4 offences will follow the Club’s appeal process which involves either a Virtual Appeal Panel held remotely or in-person as notified by the Club to the appellant and described below in further detail in the “Appeals with an Appeal Panel Hearing” section.

Appeal Process

1) Appeals with an Appeal Panel Hearing

Upon receipt of an appeal and supporting evidence, the Sanctioning Officer may reduce or withdraw the original sanction. If the sanction is not reduced or cancelled, an appeal hearing will be scheduled within thirty (30) calendar days of the appeal request being received by the Club, unless additional time

is required by the Club for further investigation. The Member or individual will be notified of any extension to the investigation period.

Where an appeal hearing date has been set and is required to be rescheduled, the appeal must be heard within two (2) months of the originally scheduled appeal hearing date. If the Member or individual does not agree to a new appeal hearing date in that time, the appeal will be considered withdrawn.

One of two appeal formats will be selected at the discretion of the Appeal Panel:

· a Virtual Appeal Panel held remotely; or

· an in-person hearing.

The Club shall have the right to schedule the date and format of the appeal hearing at its discretion and it is under no obligation to accommodate requests for the hearing to be held on a specific date or in a specific format.

The Member or individual will be invited to appeal their sanction remotely or in person to a panel, accompanied by a nominated individual or individuals who may reasonably be requested to contribute to the appeal. Members and individuals under the age of eighteen (18) must be accompanied by their parent/legal guardian who may speak on their behalf. The Club will not pay any costs (including for the avoidance of doubt any travel, accommodation and all other costs and expenses) associated with anyone attending an appeal.

The Club will present the evidence used in their investigation and the Member or individual will have the opportunity to present any evidence submitted to support their case, such as witness statements or video footage.

If a Member or an individual does not attend an agreed panel hearing on the date and in the format selected, or chooses to have the appeal heard in their absence, the Written Appeal process will apply.

2) Written Appeal

The Appeal Panel will review a written appeal and any supporting evidence submitted by the Member or individual (subject to that appeal and evidence being submitted within fifteen (15) calendar days of the Club sending the Sanction Notice). A panel will operate remotely to consider the appeal and provide a final written decision.

3) Appeal Panel Decisions

Appeal Panel decisions may withdraw, reduce, maintain or increase the original sanction and will be considered final. Minutes of the meeting will be recorded and kept on file with details shared with relevant departments within the Club.

In accordance with the Sanction Conditions in Part 3, there will be no refund of any monies paid for periods of ejection, suspension, ban or other sanction unless and only to the extent that such ejection, suspension, ban or other sanction is overturned by the Club's Appeal Panel on appeal. To the extent such ejection, suspension, ban or other sanction is overturned by the Appeal Panel, the Club will refund the cost of any Matches and/or Events paid for and missed as a result of such ejection, suspension, ban or other sanction.

If a Member or an individual is not satisfied with the outcome of the appeal, they will be advised that they can take their case to the Independent Football Ombudsman.

4) Appeal Panel Members

The Club may at its discretion appoint the individual members of the Appeal Panel, providing only that the Panel is comprised of:

· a senior member of Club staff at Head of Department level or above;

· a member of one of the Club’s Diversity Action Groups; and

· a representative of the Football Supporters’ Association.

PART 5: EDUCATION AND RESTORATIVE JUSTICE

Discriminatory Language or Behaviour and Education Sessions

The Club will insist any Member or individual found to have used discriminatory language or behaviour attend an education session with an independent equality and diversity specialist before their full sanction is determined. A failure to agree to attend such a session will result in a maximum sanction.

Restorative Conversation

The Club will insist that as a condition of returning to any of the Premises, any Member or individual found to have used violent, threatening and/or abusive language or behaviour towards other Members, Event attendees and/or members of Club staff must enter a restorative conversation process with a Club representative at the Club’s offices. Such conversation may include an educational session on the Ground Regulations and the contents of this Policy before their sanction is served.

Last updated: 13 November 2024