Supply Chain National Security

FANATICS

SENIOR MANAGEMENT COMMITMENT STATEMENT

Fanatics (the “Company”) is a leading global retailer of licensed sportswear, sports equipment and related merchandise and we supply our products and services worldwide. As a global company, Fanatics is part of an integrated customer base and supply chain that engages in a broad range of import- and export-related activities. The Company’s global operations subject such activity to US government trade laws and regulations, which requires vigilance, focus and dedication to compliance. In support of these requirements, and the legal responsibilities and business interests of Fanatics, we are implementing a sanctions and embargos compliance program that all employees are required to follow.

US laws and regulations govern our privilege to import products into, and export products out of, the United States. We seek never to jeopardize that privilege. The Office of Foreign Assets Control regulations govern and enforce economic and trade sanctions in support of U.S. national security and foreign policy objectives. These laws and regulations have applied to the Company since inception. While US national security interests sometimes change the manner in which these requirements are implemented, the fundamental obligations remain the same. Compliance with these regulations is a top priority for Fanatics.

To meet our sanctions compliance obligations, we have issued the attached Sanctions and Embargos Policy. Please reach out to the Global Legal Team with questions or for support related to sanctions or embargo compliance. Fanatics expects all employees to be familiar and compliant with sanctions regulations as they pertain to their duties and responsibilities, as well as the distribution and sourcing of Fanatics products.

Our management stands ready to assist the Company as it adapts to this updated approach. Our internal and external resources have a wealth of experience and expertise in this area, as well as the ability to navigate the complexity of the regulatory requirements and the Government agencies involved in the process. Your Global Legal Team Business Partner can get you any needed support. They will ensure we apply appropriate due diligence and conduct our activities in compliance with sanctions regulations, as well as comply with the Fanatics Sanctions and Embargos Policy.

A failure to comply with these laws and regulations, as well as Fanatics policies and procedures, subjects the Company and individuals to significant penalties — from fines to imprisonment. These risks are unacceptable and will not be tolerated. Violations of these laws or Company policies also subject employees to disciplinary action up to, and including, termination of employment. Compliance is neither optional nor discretionary. Employees who are aware of noncompliant activity should immediately report the matter to the Legal Department or anonymously through the Company’s Employee Hotline. Each Employee is responsible for sanctions compliance and we are strongest when we collectively work together to fulfill our responsibilities. We take our responsibilities seriously and expect each Employee to do so, as well.

Doug Mack, CEO

March 2021

Sanctions & Embargoes Policy

March 2021

Our mission – to amplify pride and create connections for all fans - is a common thread which unites us and drives our business forward. Creating a memorable experience for each fan who put their faith in Fanatics across our many channels and touchpoints requires unwavering discipline and attention to detail in our practices, policies and industry-leading standards.

Our Sanctions & Embargoes Policy complements our other policies such as Standards of Business Conduct and Anti-Bribery and Corruption. Please read and apply our Sanctions & Embargoes Policy, making sure your actions show respect for the fan, our partners and competitors, the community, your co-workers and yourself.

Remember that in your business interactions, you handle the ball for Fanatics.

While winning is important, it is just as important to win the right way.

Doug Mack, CEO

To address any concerns you may have or develop arising from this Policy in a prompt and fair way, please call our Employee Hotline (US/Canada: 844-***-**** or Non-North America: 844-***-**** (must dial country access code first) or see Section 4 for other options/languages) at any time, and for any reason. Reports can be made anonymously. Fanatics will never allow any form of retaliation for making a report in good faith. You may also file a report through other means, as detailed on page 4 of this Policy.

1. PURPOSE AND SCOPE

The purpose of this Policy is to provide Fanatics employees with information and assistance regarding compliance with sanctions, Embargoes and Restricted Party lists as well as reinforce Fanatics’ commitment to compliance. This policy applies to all directors, officers and employees of Fanatics, Inc. and its subsidiaries worldwide (collectively “Fanatics” or the “Company”). The policy will be implemented through standard operating procedures and controls as determined by the General Counsel from time to time.

All Fanatics employees are responsible for understanding this Policy and ensuring its uniform and effective implementation, as well as ensuring that their conduct and actions are wholly consistent with its requirements.

2. POLICY

It is Fanatics policy to strictly comply with all statutory and regulatory requirements related to Sanctions, Embargoes, and Restricted Parties that apply to its business around the world. The Company has adopted a strict policy of compliance with the following applicable sanctions, embargoes, and restricted parties lists: UN; EU; U.S., including the Sanctions, Embargoes and Restricted Party programs administered by the U.S. Department of the Treasury and its Office of Foreign Assets Control (“OFAC”), the Department of State, the Department of Commerce, the Financial Crimes Enforcement Network (“FinCEN”) and other agencies of the United States government; together with country-specific and other sanctions, embargoes and Restricted Party lists adopted in jurisdictions where the Company operates, or as otherwise applicable to its business activities. A “Restricted Party” is any entity, person, agency, organization or other party that has been identified by a governmental agency as being restricted or prohibited from exporting to, transacting with, providing services to, governmental contracts, or to otherwise engaging in business, commercial or financial transactions of any kind with as evidenced by their appearance on a government issued Restricted Party listing. An “Embargo” is an official ban by the government on trade or other commercial activity with a particular country or related to the exchange of specific goods. A “Sanction” is the imposition of controls on transactions and/or freezing of assets under U.S. jurisdiction. The U.S. Office of Foreign Assets Control (“OFAC”) administers and enforces a number of different Sanctions programs against governments, geographic regions, products, entities and individuals, which may either be comprehensive (total ban) or selective (e.g., focused on a particular sector).

All employees must exercise due care and diligence so as not to engage in business dealings with geographic regions, countries, governments, groups of individuals, individuals, entities or products subject to sanctions, Embargoes, or other trade restrictions. Employees are responsible for ensuring that (i) they do not take any actions that contravene Sanction, Embargo or Restricted Party laws or regulations; and (ii) they do not engage in any business, commercial or financial transaction, whether direct or indirect, such as: 1) sales of goods, services or technology; 2) procurement of goods, services or technology; 3) hiring of any individual or entity (e.g. distributors, consultants); and 4) travel in each case involving any country, individual or entity subject to a sanction, embargo or Restricted Party list. If an entity or individual becomes restricted, sanctioned or embargoed, the Company’s business with such entity or individual will be terminated or duly restricted, as required.

Prior to conducting, or agreeing to conduct, any business activity or transaction with any prospective or actual employee, customer, or other third party that will act on behalf of Fanatics or any business, commercial or financial transactions or activities with Fanatics, (e.g. subcontractor, licensees, supplier, vendor, service provider, consultant, attorney, sales representative, distributor, dealer, reseller, freight forwarder, customs broker, visitor, financial institution) (each a “Business Contact”), employees are responsible for contacting the Paralegal – Legal Affairs who will coordinate screening to confirm that the entity does not appear on or is not impacted by any applicable Restricted Party, Sanctions or Embargoes list.

In addition, Company employees must immediately report to the Legal Department or the Hotline any awareness that any person, entity, or country with whom the Company conducts or may conduct business is or could be subject to Sanctions, Embargoes or Restricted Party lists; any potential violation of sanctions or embargo laws or regulations; any violation of a Restricted Party listing; or any potential violation of this Policy (“Reportable Matter”). All direct reports to the CEO are responsible for ensuring that all affected employees in their respective organizations are informed as to the requirements of this Policy, and for its effective implementation locally.

All employees shall immediately refer any inquiries from persons outside the Company with respect to matters covered by this Policy, including governmental agencies, law enforcement and other authorities, to the Legal Department.

This Policy will be implemented by the Legal Department through a statement of practice (“SOP”) which shall set forth further controls and recordkeeping obligations. The Company’s internal procedures shall be updated periodically to ensure compliance with this Policy and the SOP.

3. POLICY VIOLATIONS

Violations of this Policy may cause substantial harm to the Company, including but not restricted to potential threats to the Company’s ability to secure important new licenses; loss of trust and confidence in the Company's brands among its Business Contacts, shareholders, Company employees, and regulators; significant reputational damage; and liability for the Company and Company employees. A wide range of civil or criminal penalties may be imposed for violations of sanctions, embargoes and Restricted Party lists. Non-compliance with this Policy by a Company employee may result in disciplinary action including termination of employment, liability for damages incurred by the Company, and other remedies available under applicable laws.

4. REPORTING

Upon becoming aware of any Reportable Matter, employees should immediately inform the Legal Department, providing all relevant details. The Company will investigate all reports concerning Reportable Matters in a timely manner. All reports will be addressed confidentially and objectively. The Company will protect any person who makes a good faith report from retaliation. Reports or inquiries may also be submitted through the Company’s Employee Hotline via telephone, fax, email or online 24 hours a day, 7 days a week. Our hotline is administered by a third party, Lighthouse Services, and may be submitted as follows:

•Website: www.lighthouse-services.com/fanatics

•Direct Dial and Toll-Free Telephone:

-English speaking USA and Canada: 844-***-****

-Spanish speaking USA and Canada: 800-***-****

-French speaking Canada: 855-***-****

-All other countries: 844-***-**** (must dial country access code first)

•E-mail: ad5d86@r.postjobfree.com (must include Fanatics as the company name with report)

•Fax: 215-***-**** (must include Fanatics as the company name with report)

When making a report, you may choose to remain anonymous. However, please provide as much information as possible (e.g. names, dates, locations or descriptions) in order to assist our investigation.

5. WHAT ARE SANCTIONS, EMBARGOES, AND RESTRICTED PARTIES?

Given the global scope of the Company’s business, the Sanctions, Embargoes, Restricted Party regimes of different jurisdictions may apply to specific activities, depending on the circumstances of the transaction. Whether and when Sanctions, Embargoes or Restricted Parties apply to a particular aspect of the Company’s business requires the review of the Legal Department.

Many of the countries in which the Company operates have adopted sanctions, embargoes, and Restricted Party lists of various types, and some are subject to multiple sets of rules. The U.S. takes a very broad and extraterritorial view of the application of its Sanctions, Embargoes, and Restricted Party laws and regulations. In most cases, U.S. laws and regulations apply to U.S. citizens, and U.S. permanent residents, wherever they are located, and individuals and entities located or incorporated in the U.S. (including all foreign branches and subsidiaries thereof), corporations organized under U.S. law, including foreign branches and entities owned or controlled by any of the above the most important being foreign-organized subsidiaries of U.S. corporations. However, various aspects of the Company’s activities, USD-denominated payments that are routed through U.S. correspondent banks, the involvement or employment of U.S. persons by the Company, the acquisition of U.S. technology or software, or the incorporation of U.S. parts and components, will also result in the application of these U.S. rules. The U.S. has also established “secondary sanctions” that target non-U.S. persons engaged in certain activities (for example, business with Iran), even when they are not connected with the U.S.

Sanctions and Embargoes regulations, and Restricted Party lists, change frequently, as they are subject to revision as foreign policy and national security interests change. Restrictions may be (i) country, individual, entity, activity or product specific; (ii) comprehensive, prohibiting all activity; or (iii) block or freeze accounts or property of identified entities or individuals. Sanctions and Embargoes may prohibit or further restrict business activities with entities or individuals expressly named on a Restricted Party list, as well as with subsidiaries or affiliates of such persons that are not expressly named; or with specified countries, regions territories or governments.

Further information about these Sanctions, Embargoes and Restricted Party lists are available from the Legal Department.

6. UPDATES

This Policy and the SOP will be reviewed by the Legal Department at least annually, and where necessary updated to reflect changes to external laws and regulations and internal risk assessments and controls.

[End of Policy]

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