Archie Bruce

FAO HM Senior Coroner Martin Fleming 
Sent By Email and Unsigned 

4th Floor 
Trinity 
16 John Dalton Street 
Manchester  
M2 6HY 
United Kingdom 

kennedyslaw.com 

10 June 2024 

  Dear Sir 

  INQUEST TOUCHING THE DEATH OF ARCHIE CAMPBELL BRUCE 

Introduction 

We act on behalf of the Rugby Football League (“RFL”).  

We  write  following  the conclusion  of  the  above  inquest,  and  to  respond  to  the  report to 
prevent future deaths (“the report”), dated 18 April 2024, addressed to the RFL.  

This report sets out a number of concerns raised by HM Senior Coroner, Martin Fleming (“the 
Coroner”) as a consequence of evidence heard at the above inquest, and following his review 
of  submissions  received  from  the  interested  persons  at  the  conclusion  of  the  inquest 
proceedings.  

The concerns raised by the Coroner are as follows: 

1.  I  have  noted  that  the  Welfare  Policy  and  Standards  provides  provision  for  Clubs 
outside  the  Super  League  to  apply  for  a  dispensation  primarily  on  the  basis  of 
resources. 

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 2.  I  would  ask  that  consideration  be  given  to  the  appropriateness  of  amending  this 
provision so that  there is  not  a relaxation of  the  rules in clubs  outside the Super 
League, given that it is clubs outside the Super League where young players start 
off  their  careers,  and  given  their  immaturity  are  more  likely  to  benefit  from 
education and a defined Code of Conduct. 

3.  RFL to consider the appropriateness of overarching guidance, education and training 
with respect to the code of conduct without dispensations, with regard to the use 
of both illicit drugs and misuse of prescription drugs, in order to ensure consistency 
of application of education throughout all tiers of the sport. 

This letter sets out the RFL’s response to the Coroner’s concerns. Please note, the policies, 
procedures,  guidance  and  training  information  referred  to  in  this  response  are  those 
exclusively focussing on the professional game of rugby league. There are different standards 
and expectations in relation to the amateur and grass roots game.  

Background 

The inquest touching the death of Archie Campbell Bruce was heard before the Coroner at 
Bradford Coroners Court on 17 January 2024. During the inquest proceedings, the Coroner 
heard that Archie was a promising young rugby league player who played his debut match 
for Batley Bulldogs against Toulouse Olympique on 17 August 2019. After socialising with his 
teammates and others after the match, Archie was tragically found deceased in his hotel 
room the following morning.  

During the inquest the Coroner heard evidence from a number of the Batley Bulldogs players 
and  staff  via  agreed,  written  statements.  The  Coroner  also  heard  oral  evidence  from  Dr 
Faisal Ali, DC Lorna Ratcliffe, and Mr Kevin Nicholas. Mr Nicholas is the Chairman of Batley 
Bulldogs and was in attendance at the match against Toulouse, and present for part of the 
social  activities  post-match.  Mr  Nicholas  gave  evidence  regarding  the  changes  which  had 
been made at the club as a consequence of Archie’s death. No witnesses from the RFL were 
required to give evidence at the inquest. Further, prior to the inquest, neither the Coroner 
nor any of the interested persons had requested to be provided with any information from 
the RFL. 

In concluding the inquest proceedings, the Coroner invited both Batley Bulldogs, and the RFL 
to provide written representations to assist him in considering whether to make a report to 
prevent future deaths.  

Written submissions were duly sent to the Coroner, on behalf of the RFL, on 30 January 2024. 
It  seems  there  may  have  been  some  confusion  regarding  the  role  of  the  RFL,  and  the 
application of its policies, procedures and guidance which were sent to the Coroner with the 
RFL’s previous submissions. In response to the report, we respectfully reiterate some of the 
points made within these earlier submissions. 

The RFL 

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 The RFL is the national governing body for Rugby League in the United Kingdom. It governs, 
regulates and develops the sport of Rugby League. The RFL currently employs approximately 
100 people on a full-time basis across a range of departments which include development, 
participation, operations and legal, match officials, finance and HR.  

The  departments  within  the RFL  include  the  Professional  Game  Delivery  Team  (“PGDT”), 
which consists of 6 employees and is responsible for overall delivery of competitions within 
the Professional Game. The PGDT is overseen by the Head of Delivery of Professional Game 
Competitions. 

The  PGDT  is  responsible  for  the  compilation  and  management  of  all  fixtures  and  results 
across  Tier  1-3  Competitions  and  management  of  on-field/off-field  disciplinary  and 
misconduct functions, depending on the league concerned. The PGDT oversees Professional 
Game player registrations (scholarship to open age), coaches and club staff. Additionally, 
the PGDT leads on accreditation for coaching, insurance and clubs.  

Batley Bulldogs and Toulouse Olympique 

Batley Bulldogs  is  an English rugby league club based in Batley, West Yorkshire. The club 
currently play in the RFL Championship. 

The RFL Championship is the second tier of rugby league, sitting one competition below the 
Super League.  

The  league  consists  of  14  teams,  with  promotion  to  the  Super  League  via  a  playoff,  and 
relegation to League One. 

The Championship consists of both full time professional clubs and also semi-professional 
clubs.  Batley  Bulldogs  is  a  semi-professional  club.  To  clarify  earlier  submissions  made  on 
behalf of the RFL, a full time professional club is one that is made up exclusively of full time 
professional  players  and  staff.  A  semi-professional  club  will  include  some  full  time 
professional players, but will also include part time players and staff. The ratio of full time 
professional players to part time players is club dependant.  

Toulouse Olympique is a full time professional club which also plays in the RFL Championship. 
Each team in the RFL Championship plays each other twice, once at home and once away. 
At the time of Archie’s tragic  death, Batley Bulldogs had travelled to Toulouse to play its 
away fixture.  

The game between Batley Bulldogs and Toulouse Olympique was a regular fixture in the RFL 
Championship calendar.  

Overseas Travel – Code of Conduct for Squads 

When  playing  overseas  fixtures,  the  RFL  expects  all  Players  and  Club  Officials  to  act  as 
ambassadors for their Club, and for the game of rugby league.  

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 The  RFL  have  an  Overseas  Travel  Code  of  Conduct  for  Squads  which  has  previously  been 
provided to the Coroner. This code of conduct requires that all Players and Club Officials 
comply with a number of expected standards, including (amongst others): 

•  Players are to be courteous to hotel staff, coach drivers and airport/airline staff at 

all times; 

•  Drinking to excess is prohibited and all Players must be made aware in advance of 
the Club’s disciplinary procedures to which they will be subject should they disregard 
this instruction; and 

•  The  Club  should  appoint  a  senior  person  to  take  responsibility  for  both  enforcing 
these rules and to handle any incident of misbehaviour. This person should be the 
Head Coach, Chief Executive or a Club Director.  

The Overseas Travel Code of Conduct applies to all clubs in the professional game, without 
exception, and regardless of the number of full time professional players a club may have.  

As  previously  confirmed,  anyone  found  to  be  involved  in  unacceptable  behaviour  whilst 
playing abroad may find themselves being charged with off field misconduct which would 
result in possible sanctions ranging from a fine, education to suspension.  

Player Welfare Policy 

The  RFL  treats  the  welfare  of  all  players  as  a  paramount  concern.  The  RFL’s  vision  is  to 
deliver the best player welfare and education programme in British sport.  

The RFL works closely with rugby league clubs to deliver a Player Welfare Policy. The Player 
Welfare Policy in place at the time of Archie’s tragic death has previously been provided to 
the Coroner.  

The aim of the Player Welfare Policy is to ensure that players:  

•  Can play to the best of their abilities unhampered by off field concerns; 

•  Are proud advocates of rugby league and act as good role models and spokesmen for 

the sport; 

•  Understand the responsibilities of life in the public spotlight as professional sports 

people; 

•  Have good life skills, show respect to all and make wise decisions; and 

•  Develop mental resilience and understand how to look after their mental health and 

avoid addiction.  

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 The  Player  Welfare  Policy  is  comprehensive  and  includes  standards  and  expectations  in 
relation to both alcohol, and social and prescription drugs.  

In relation to club cultures, the Player Welfare Policy states that clubs should ensure that 
the  environment  does  not  include  a  drinking  or  gambling  culture.  The  club  should  put  in 
place  suitable  protections  and  alternatives  for  players  with  alcohol  or  other  addictions, 
particularly on club bonding trips. Each club must have an alcohol and gambling policy which 
is supportive of this approach.  

All clubs should have a Player Welfare Manager who is responsible for looking out for the 
signs of excessive drinking amongst players.  

Player Welfare Managers are also responsible for driving the RFL’s Social and Non-Prescribed 
Prescription Drug Policy within their clubs.  

The Coroner is correct to note that the Player Welfare Policy includes a provision for clubs 
outside the Super League to apply for a dispensation from its application, primarily on the 
basis  of  resources.  All  clubs  playing  in  the  Super  League  are  full time professional  clubs. 
Clubs  in  the  Championship,  and  League  1  will  include  both  full  time,  and  part  time 
professional clubs. The reason the provision applies therefore, is to allow clubs with very 
few full time professional players (perhaps even as little as one professional player) to apply 
for  a  dispensation  from  some  of  the  requirements  of  the  Player  Welfare  Policy.  This  is 
primarily on account of resources.  

It should be noted however, that there are limits to when a dispensation would be granted. 
This decision would be taken by the RFL Board, and would be based on the merits and facts 
of each case.  

The RFL has previously provided a copy of its Social and Non-Prescribed Prescription Drugs 
Policy (the Policy), details of which are set out again below for convenience. An application 
for dispensation from compliance with the Policy has never been received by the RFL, and 
if it were to be received, would not be granted.  

In fact, it should be noted that the RFL has not received any applications for dispensation 
(on any grounds) from any club currently playing within the professional game (incorporating 
tier 1 through to tier 3). Bearing this in mind, and acknowledging the Coroner’s concerns, 
the RFL are of the view the provision to allow clubs to apply for a dispensation from the 
Player  Welfare  Policy  is  in  fact  no  longer  necessary.  The  RFL  are  therefore  considering 
removing this provision from the latest draft of the Player Welfare Policy and Standards.  

Drug Misuse in Rugby League 

As the Coroner is aware, the RFL works closely with UK Anti-Doping (“UKAD”) to achieve and 
champion clean sport across both the professional and community game. Rugby League, as 
with  all  sports,  is  governed  by  the  World  Anti-Doping  Agency  (“WADA”),  and  every 
participant is subject to the RFL’s Anti-Doping Rules. 

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 The RFL is committed to the principles of clean sport to uphold and preserve the integrity 
of the game, to safeguard the physical and mental health of Players, and to ensure that all 
Players have the opportunity of competing equally.  

To underpin its commitment to the principles of clean sport the RFL aims to educate and 
inform Players about the dangers of drugs and the consequences of taking drugs.  

At  the  time  of  Archie’s  death,  the  2015  Anti-Doping  Code  was  in  effect.  This  code  was 
updated in 2021.  

As at the time of Archie’s death, a Player would be committing an Anti-Doping Rule Violation 
if: 

•  A prohibited substance and/or prohibited method is found in his bodily specimen; 

•  He were to use or attempt to use a prohibited substance; 

•  He avoids or refuses to undertake a drug test; 

•  He fails to provide his whereabouts for out of competition testing, or gives inaccurate 

whereabouts details leading to a missed test; 

•  He tampers, or attempts to tamper with any part of the doping control process; 

•  He possesses a prohibited substance; 

•  He administers or attempts to administer a prohibited substance, or assist, encourage 

aid, abet, or cover up an anti-doping rule offence; 

•  He traffics a prohibited substance; 

• 

Is complicit in an anti-doping rule break committed by another Player; or 

•  Associates with a person, for example a coach or Doctor, who is serving a suspension 

for a doping offence. 

To support Players in accessing relevant anti-doping information, the RFL prepared a “Anti-
Doping Booklet. A copy of this booklet has previously been provided.   

The RFL also has a Social and Non-Prescribed Prescription Drug Policy, as referred to above. 
A copy of the Policy which was in place at the time of Archie’s death has previously been 
provided to the Coroner.   

The Policy aims to achieve a number of objectives, including: 

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 •  To prevent players from causing long or short term damage to their health/mental 

wellbeing through misuse of illegal or non-prescribed substances; 

•  To ensure that players can be offered appropriate treatment before misuse and/or 

addiction jeopardises their careers; 

•  To protect other players who may be put at risk by players who train or play under 

the influence of social or non-prescribed prescription drugs; and 

•  To protect the reputation and integrity of the game.  

To  meet  these  objectives  the  RFL  adopts  an  integrated  approach  which  is  intended  to 
educate, deter, and rehabilitate those involved with the misuse of social and non-prescribed 
prescription drugs.  

From  time  to  time  the  RFL  will  provide  workshops  to  help  educate  players  on  the  RFL’s 
Policy. The RFL also encourages Clubs to remind its players of the RFL policy on an annual 
basis.  

The RFL abides by the UK Anti-Doping Rules and works with the UK Anti-Doping Agency to 
ensure  compliance  with  the  WADA  Code.  Testing  is  generally  completed  at  random  and 
decided by UKAD.  

In terms of rehabilitation, welfare and/or disciplinary procedures, the Policy adopts a three 
violation procedure, as follows: 

•  First  violation –  following a  first violation of the Policy  players will be required to 
attend  an  initial  case  review  with  the  RFL  and  the  clubs  Doctor/Player  Welfare 
Manager. Following the review the player will be required to attend an assessment 
with  a  representative  of  the  RFL’s  Counselling  and  Addiction  Service.  Subject  to 
compliance with the assessment/counselling, there will be no further action.  

•  Second violation – following a second violation for social drugs clubs will be able to 
take such internal disciplinary action as they consider necessary including dismissal 
and/or fines. In the case of a second violation for non-prescribed prescription drugs, 
the process as set out under the first violation will be followed, but clubs can take 
additional disciplinary action including fines, and a written warning, but not including 
dismissal.  

•  Third violation – for social drugs the process is the same as set out for the second 
violation. In the case of a third violation for a non-prescribed prescription drug a club 
can take disciplinary action including a fine and or written warning, but not including 
dismissal.  

For any subsequent violations a club may take disciplinary action and/or dismiss the player.  

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 Players are encouraged to self-declare in the event they have used social or non-prescribed 
prescription drugs. Where a player approaches the RFL or an appropriate member of club 
staff and self-declares that he has used a social or non-prescribed prescription drug prior to 
screening being carried out, the process set out under the first violation will be followed, 
but it will not be recorded as a first violation.  

For the purpose of the above, a non-prescribed prescription drug is defined as a prescription 
drug for which the player cannot provide evidence of a prescription. For the purpose of the 
policy  in  place  at  the  time  of  Archie’s  death,  Tramadol  was  considered  to  be  a  non-
prescribed prescription drug, not a social drug.  

Cocaine is classed as a social drug. Its use would never be condoned by the RFL either during, 
our outside of the playing season.  

Tramadol has been on the World Anti-Doping Agency (WADA) Monitoring Program for several 
years  and  data  gathered  through  this  programme  has  indicated  significant  use  of  the 
substance in a number of sports.  

Tramadol misuse is of concern because of the risks of physical dependence, opiate addiction 
and overdose.  As a  consequence, Tramadol was  prohibited  in-competition when the 2024 
WADA Prohibited List came into effect on 1 January 2024.  

Mandatory Training 

For  the  Professional  Game  (encompassing  Men’s  and  Women’s  first  teams,  reserves  and 
academy) Clubs are expected to assist with the delivery of mandated education. Clubs are 
given  a  set  time  frame  for  each  player,  support  staff  and  those  persons  subject  to  the 
Operation Rules to complete a set of online modules.  

This  year  the  RFL  changed  things  slightly  and  required  Clubs  to  complete  the  modules  2 
months ahead of the season starting. If a new player joined, the Club was to ask for that 
player to be invited to complete the training by providing their name and email address.  

The modules are hosted on the RFL’s “Our Learning Zone” (the RFL’s education site, hosted 
on  the  HIVE  platform).  This  year  the  RFL  have  covered  topics  including:  Anti-Doping, 
Concussion, Gambling and Equality, Diversity and Inclusivity. These were identified by the 
RFL as critical modules to deliver to the Professional Game.  

Should players not have completed the modules they are stood down from playing until each 
module is completed. The RFL took this action for the first time this year to ensure Clubs 
bought into the education piece and understood its importance.  

The online modules have run in ‘education week’ format for 3 years (Covid prompted a real 
need to host modules online to supplement face to face delivery – which during covid was 
via Teams/Skype).  

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 Prior to the online modules, face to face delivery was provided to Clubs and was mandated, 
alongside  documentation  provided  with  support  from  Clubs  Player  Welfare  Managers  on 
various  topics.  The  Anti-Doping  sessions  were  provided  by  UKAD  accredited  educators  to 
Clubs, other aspects of education have been delivered by Welfare Managers or other external 
providers. 

The  RFL  will  review  mandatory  training  requirements  each  year,  and  in  the  event  of  a 
significant issue being identified. 

Conclusion 

As  set  out  above,  the  RFL  has  comprehensive  policies  and  procedures  in  place  which  it 
expects clubs to adhere to. Clubs are responsible for applying and adhering to the RFL codes 
of conduct, player welfare policies and drug policies.  

In  summary,  the  RFL  do  not  believe  that  its  current  policies,  procedures  and  training 
information are  deficient,  or  indeed would contribute in any way to a death occurring in 
similar circumstances to the sad death of Archie Bruce. Notwithstanding this, the RFL have 
carefully considered the Coroner’s concerns, and will give further consideration to removing 
the provision allowing clubs to apply for a dispensation from the requirements of the Player 
Welfare Policy and Standards – despite no club seeking to rely upon this provision.  

The RFL has already introduced changes to its policies and procedures since Archie’s death 
as  a  consequence  of  its  annual  review  process.  In  addition,  the RFL will  be  reviewing  its 
Overseas  Code  of  Conduct  with  specific  reference  to  player  behaviour  and  how  it  can 
safeguard more impressionable younger/less experienced Players. This will take place this 
year in accordance with its regulatory review process. It is not right that it is clubs outside 
the Super League where young players commence their careers. The majority of professional 
players are scouted by the academies of Super League Clubs, who are all required to adhere 
to the RFL policies and procedures.  

Many other players who make their way into the professional game come through the England 
Community  Lions  programme.  This  is  a  centrally  run  programme  that  provides  playing 
opportunities for those who do not make scholarship at 15. The RFL provides touring and 
playing opportunities to these players and as part of the work undertaken with these players, 
the  RFL  undertakes  education  on  a  number  of  topics  including  good  life  choices,  drugs, 
alcohol and welfare.  

The RFL are satisfied that it currently provides appropriate guidance, education and training 
with respect to the code of conduct, with regard to the use of both illicit drugs and misuse 
of  prescription  drugs.  In  the  event  the  Player  Welfare  Policy  is  amended  to  remove  the 
provision to allow a club to apply for a dispensation from the requirements of the Player 
Welfare Policy, ongoing training will of course reflect these changes. 

We  trust  the  above  information  adequately  address  the  concerns  raised  by  the  Coroner. 
Finally,  the  RFL would  like  to  once  again  pass  its  sincere condolences to  the  friends  and 

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 family  of  Archie  Bruce.  It  is  evident  that  Archie  was  a  very  talented  young  rugby  league 
player who had a very bright future ahead of him. 

Yours sincerely 

Legal Director 
for Kennedys 

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