From Trading Floors to Training Grounds: Why Football Clubs Need a Conduct Risk Framework

The Championship Play-Off Final is often referred to as the richest game in football. Earning promotion to the Premier League can be worth around £220 million, dramatically transforming a club’s financial future almost overnight. With such high stakes, the quest for a competitive advantage becomes relentless.

It was in this context that the English Football League’s recent “Spygate” decision emerged.

At C&G Regulatory Solutions, this case sparked significant interest. Our CEO, Alex Culley, is a lifelong Southampton supporter, while the firm’s newest recruit, Logan Golden, is a passionate Middlesbrough fan. Like many supporters, we engaged in discussions about the decision, the sanctions imposed, and the wider implications for the game.

However, as compliance professionals, we found ourselves pondering a different question. Instead of asking whether Southampton breached the rules, since that has already been determined, we considered what this case reveals about governance, culture, and the value of a conduct risk framework in elite football.

Our conclusion is that it reveals quite a lot.

Football has become a conduct-risk business: protecting market integrity

Before exploring the lessons, it is worth explaining what we mean by “conduct risk”. In financial services, conduct risk is the risk that poor decisions, behaviours or organisational culture led to outcomes that harm customers, markets or confidence in the financial system. Increasingly, elite football faces comparable risks – not to investors, but to the integrity of sporting competition itself. The underlying governance challenge is remarkably similar.

At first glance, professional football and Financial Conduct Authority (FCA)-regulated investment firms might appear to be worlds apart. Football captivates millions of fans every weekend, while investment firms focus on capital allocation, risk management, and the support of vibrant financial markets.

Yet, when we dig a little deeper, the similarities become quite compelling. Both sectors are in a global race for talent, continuously seeking that slight edge through advanced data and analytics. Each operates within regulatory frameworks designed to ensure integrity, and both depend on high-performing specialists whose choices can significantly shape their success. Moreover, considerable financial rewards await those who excel, and both arenas ultimately thrive on trust.

For financial markets to operate smoothly, participants must believe in their fairness, orderliness, and robust oversight. Similarly, the essence of football lies in the trust shared among its stakeholders, including supporters, clubs, players and broadcasters, all of whom believe in the fairness of the competition..

This shared perspective is reflected in regulators’ language. In the Southampton case, the Independent Disciplinary Commission stressed the vital importance of public confidence in sporting integrity, a sentiment echoed by the FCA in its mission to safeguard and enhance the integrity of the UK financial system. At the core of both industries lies a fundamental truth: confidence is essential.

This realisation prompts a valuable shift for football clubs. By embracing a mindset akin to that of regulated organisations, clubs can navigate conduct risks with the same diligence found in the financial sector, ensuring a fair and trustworthy sporting environment.

Developing a clear conduct risk strategy is an important first step towards creating an environment where integrity and performance can coexist.

Lesson One: Culture starts at the top

One of the key lessons learned by the financial services sector over the past two decades is that misconduct often doesn’t stem from a lack of rules within organisations. In fact, most regulated firms have numerous rules in place. Problems typically arise when the organisational culture encourages individuals to stretch, rationalise, or ignore those rules.

The FCA’s enforcement action against Sigma Broking illustrates this point well. Rather than focusing solely on individual misconduct, the FCA examined the firm’s governance arrangements, board oversight, systems and controls, risk management framework and compliance function. The case demonstrates how modern regulators increasingly look beyond individual failings to assess whether an organisation’s control environment can support compliant behaviour.

Similar questions are increasingly being raised in football cases. For instance, in the case of Southampton, the disciplinary body did not treat the matter as merely the isolated behaviour of one individual. Instead, it examined how the activity was planned, who was aware of it, how junior staff were involved, and what this revealed about the organisation’s broader approach to complying with the rules.

This theme appears again, albeit in a different context, in recent Profitability and Sustainability Rules cases involving Everton and Nottingham Forest. These cases weren’t about match-day conduct; they focused on financial governance. Yet, they reflect the same regulatory instinct: football authorities are increasingly willing to impose sporting sanctions where financial governance failures threaten the sporting and financial integrity of league competition.

The lesson is clear: Football clubs should not only ask whether they have rules in place. They must also consider whether their culture supports compliance with those rules, especially during challenging times. 

Do employees receive rewards solely for achieving results? 

Are managers encouraged to challenge poor judgment? 

Are boards being provided with meaningful information regarding integrity risks?

When leadership prioritises winning at all costs, the behaviour of employees quickly reflects what is truly expected of them.

Lesson Two: Psychological safety is a governance control

One of the most significant aspects of the Southampton case concerns junior staff. Evidence suggests that relatively junior employees often find themselves carrying out instructions they feel unable to challenge. The financial services sector has become increasingly aware of this issue. Behavioural science indicates that people are less likely to challenge authority than they might believe. Factors such as authority bias, conformity, and career anxiety can lead individuals to make decisions they wouldn’t make in a healthier environment.

This highlights the importance of ensuring psychological safety as a critical governance control that can also reduce operational risk. A junior analyst at a football club who feels unable to question an instruction is not fundamentally different from a junior trader, analyst, or operations employee at a financial firm who feels they cannot challenge a senior revenue generator.

Although the FCA has not established a formal “psychological safety” programme, its work on organisational culture, whistleblowing, behavioural science and non-financial misconduct consistently emphasises the importance of effective speak-up arrangements and environments in which employees feel able to challenge inappropriate behaviour. The danger is not always a rogue individual acting alone. Often, the greater risk lies in a workplace where employees recognise that something feels wrong but do not feel safe enough to voice their concerns.

Every club should encourage its staff to feel comfortable saying, “I don’t think we should be doing this.” If that statement cannot be expressed safely, the club has a governance problem.

Lesson Three: Information should be treated as an asset

Modern football thrives on information. Think training routines, fitness levels, updates from the treatment room, talent scouting reports, nutritional analysis, performance data and tactical assessments. Anything to get that edge… 

Information is a valuable commodity but potentially also a serious liability, a fact long understood in financial services. Accordingly, investment firms use information barriers, restricted-access controls, wall-crossing policies and procedures, and market-abuse controls to govern how information is obtained, shared, and used.

Of course, most information gathering is legitimate. Studying match footage to analyse opponents is akin to gathering market intelligence using publicly available sources in the financial world. However, as the Spygate affair demonstrates, it is how information is obtained that matters. 

In financial services, if a firm improperly obtains information, it cannot then defend itself by saying that improperly obtained information turned out not to be useful or did not ultimately change the result of a trade. The regulatory concern arises from attempts to obtain or use information in a way that undermines market confidence. The comparison is not that Southampton’s conduct constituted market abuse – it plainly did not. Rather, both regulatory systems seek to preserve confidence by preventing participants from obtaining an improper informational advantage. This is where Southampton’s Spygate case most closely resembles thinking on market abuse. The issue was not merely whether the club actually won because of the information (on all three known occasions (vs Oxford United, Ipswich Town and the first leg against Middlesbrough, it didn’t). The issue is whether the conduct undermined confidence in the fairness of the competition.

Lesson Four: Outcomes are not the whole story

Football is primarily outcome-driven. Did the team win? Did the tactic succeed? Did the player perform well? However, conduct risk is assessed not just by outcomes.

In financial services, firms often get into difficulty when they assume that the absence of obvious harm means the absence of misconduct. The FCA generally takes a different view. Weak systems and controls can be serious even where no customer loss or market disruption is ultimately proven.

The Citigroup Global Markets case is a good example. The FCA’s concern included weaknesses in trading controls, monitoring and escalation. The regulatory point was not simply whether the worst possible consequence occurred. It was that controls were insufficient for the risks being run.

Football should take the same lesson. A club should not wait until potential misconduct becomes actual misconduct before taking governance seriously.

Everton and Nottingham Forest also demonstrate the broader point. Financial governance failures in football can lead to sporting consequences. The fact that breaches may arise off the pitch does not make them less relevant to the integrity of the competition. Points deductions, transfer restrictions, and disciplinary sanctions are all measures football regulators use to protect the league’s credibility.

That mirrors the approach taken in financial services. Where confidence is at stake, regulators intervene before the whole system is damaged.

Lesson Five: Good governance creates competitive advantage

Compliance is often portrayed as a department that slows things down.

In our opinion, that is a poor description of good compliance. The best governance frameworks do not prevent organisations from competing. They enable them to compete confidently. This is because:

• employees understand expectations;
• decision-making becomes faster because boundaries are clear;
• escalation routes are known;
• boards receive better information; and
• reputational risk is reduced.

In financial services, well-run firms understand that governance is not merely a regulatory obligation. It is part of being commercially sustainable.

We believe football clubs should adopt the same mindset. After all:

• coaches should not have to guess whether an intelligence-gathering exercise is permissible;
• performance analysts should not be left making ethical decisions without support;
• junior employees should not feel forced to choose between following instructions and protecting their integrity; and
• boards should not learn about conduct risk only after a disciplinary charge has been issued.

In short, good governance removes uncertainty before difficult situations arise.

What a football conduct risk framework could look like

A football conduct risk framework need not be complex. It should start with a fundamental question: Where might the pressure to win lead to inappropriate behaviour? From this starting point, clubs can identify key risks, which may concern:

• conducting intelligence on opponents;
• player recruitment;
• the use of confidential information, including betting;
• cyber security and protection of sensitive sporting data; 
• financial management reporting;
• relationships with agents and intermediaries;
• the collection of medical and performance data;
• the treatment of junior staff; and
• communications with regulators and leagues.

For each identified risk, clubs should define acceptable conduct, escalation procedures, controls, and oversight measures. This does not mean directly adopting the FCA Handbook for football. Rather, it involves applying established governance principles to a sector that is increasingly sophisticated, valuable, and vulnerable to integrity risks.

Conclusion: Governance in a changing regulatory landscape

The Southampton Spygate decision should be seen as a pivotal moment in football, highlighting a broader evolution in the sport. As football becomes more regulated, data-driven, and financially significant, it also faces increasing conduct risks.

The financial services industry has already travelled this path, discovering that simply implementing rules isn’t enough. True transformation comes from fostering strong governance, culture, leadership, and accountability.

For years, football has pursued marginal gains through sports science, recruitment analytics, performance psychology and data. Its next competitive advantage may lie somewhere less glamorous but equally important: governance. Building a culture in which doing the right thing becomes the easiest thing to do may ultimately prove just as valuable as any tactical innovation.

How C&G Regulatory Solutions can help

Many governance challenges currently emerging in professional sports have long existed in financial services.

At C&G Regulatory Solutions, we assist organisations operating in highly regulated and high-pressure environments in strengthening governance, managing conduct risk, and cultivating cultures that support better decision-making.

Our experience advising investment firms, trading venues, payment institutions, and other regulated businesses has revealed that effective governance does not slow organisations down. Instead, it enables them to compete successfully while safeguarding the confidence that their business relies on.

Through governance reviews, conduct risk assessments, behavioural culture programmes, board training, and independent investigations, we believe that many lessons learned in financial services can be effectively applied in elite sports.

After all, whether an organisation competes on the trading floor or the training ground, lasting success is grounded in the same fundamental principle: trust.