ICDS/2023/PI/1

Guidelines on sport
integrity
Revised version

April 2023

For information

Outcome document of the Global Written Consultation of States

Parties, Territories and Observer Member States within the framework

of the International Convention against Doping in Sport

*purports to the endorsement of the ninth session of the Conference of Parties

Decision BureauCOP/2023/38
Table of Contents

Foreword

Preface

Executive Summary

Part 1: Sport and integrity: Background and concept

Integrity of sport

Moving to a broader approach to sport integrity

Proposal for a holistic definition

Part 2: A comprehensive approach to sport integrity issues

Introduction

Sharing responsibility for sport integrity outside of the autonomous sports organisations

Sport integrity - Existing obligations

The relationship between risk and integrity

Assessing and dealing with risk

The role of the state authorities

Part 3: Integrity without boundaries – Elements which cross-cut the five policy areas

A) Multi-stakeholder initiatives
B) Whistle-blowers and free media
C) Protection of Human Rights
D) Education, prevention and awareness-raising
E) Monitoring implementation and compliance – and providing remedies
F) Gender and youth mainstreaming in sport integrity policies

Part 4: Compendium of factsheets on the five policy areas

Factsheet 1 - Preserving the rights, safety and security of athletes, spectators, workers and
other groups involved

3
Factsheet 2 - Preventing and addressing harassment and abuse in sport

Factsheet 3 - Fostering good governance of sport organisations

Factsheet 4 - Strengthening measures against the manipulation of sports competitions

Factsheet 5 - Ensuring an adequate anti-doping policy framework, its implementation and

effective compliance measures

Conclusion

4
Foreword to be added prior to final publication
Preface

These Guidelines are the outcome of Action Line III of the UNESCO Kazan Action Plan (KAP),
triggered by MINEPS VI (the International Conference of Ministers and Senior Officials
Responsible for Physical Education and Sport) in July 2017.

The concept development, design and elaboration of this document has then taken place over a
period during which the awareness of the impact of sports activities has significantly increased.
This is evidenced by a growing number of initiatives, conventions, resolutions, programs, forums
and meetings at local, national, regional and international levels.

At the same time as thisU explosion in the understanding of the socio-economic impact of sport
carries with it an appreciation as to the importance oft, its integrity has emerged as a theme with
similar serious consistenin the sport fieldce. Given that sport occupies such a significant part of
society, it would be naive to expect that it is immune to the problems of society. Sport as a whole
is therefore Year after year, sport appears moreincreasingly determined to robustly protect itself
from crime, fraud and other misbehaviours. And with sport such a significant part of society, it
would be naive to expect that the sector is immune to the problems of society.

The ‘UNESCO MINEPS process’ as a whole - which has moved from Berlin 2013 through the
renewed Charter in 2015 to Kazan 2017 and Baku 2023 (and is currently targeting MINEPS VII in
2021) - is proving itself to be a crucial driver in raising awareness and empowering national
Ministries of Sport and other stakeholders all around the world to act to protect sport from
threats to its integrity. The framework of stimulus, networking, exchange of practices, data,
expertise and codified know-how provided by the process is ensuring steady growth in both the
capacity and determination of all parties to take such actions.

The Council of Europe has facilitated the development of the Guidelines on sport integrity, dated
April 2020. The GuidelinesGuidelines, a draft of which was were endorsed by UNESCO’s
Intergovernmental Committee for Physical Education and Sport (CIGEPS) in September 2020.
In line with Decision Bureau COP/2022/11 and Decision Bureau COP/2022/29 of the Bureau of
the eighth of the session of the Conference of Parties (COP8) to the International Convention
against Doping in Sport, and withto Resolution CIGEPS/2022/4 of CIGEPS, it was agreed that a
review process of the Guidelines on sport integrity would be undertaken to ensure alignment
with thise Convention, including its principles, scoping, instruments and modalities.

A Global Written Consultation was conducted among States Parties to the Convention, Territories
and Observer Member States from 5 December 2022 until 21 February 2023.
Thise current version of the Guidelines is the result of this UNESCO consultation.

These Guidelines on Sport Integrity are, on the one hand, an outcome of this on-going
intergovernmental and multi-stakeholder co-operation and, on the other, the expression of a first

6
attempt to elaborate a holistic and coherent approach to this issue. They emerge from the point
of view of policy-makers and, unlike previous approaches, the guidelines now go beyond the
simple sum of different areas, like doping, match-fixing and other emerging crimes. Their
potential effectiveness is underscored by the fact that, in response to a UNESCO’s consultation,
97% of responding Governments indicated that the Guidelines would be utilised in relation to
their commitments under the UNESCO International Convention against dDoping in Sport.

Our The model benefits from a combination of the outstanding expertise matured over the years
by the Council of Europe in the field of sport integrity; the valuable experience offered from the
UNESCO International Convention against Doping in Sport; and contributions delivered by States
Parties. The latter’s inclusion has been vital in ensuring that the approach can accommodate all
necessary regional, territorial, cultural and evolution-stage idiosyncrasies. In particular, States
Parties have been a valuable contributor to the best practices referred to within this document.

As a result, the international community and national governments can now benefit from a
uniquely orientated tool. We hope it will inspire and accompany the assessment, design and
implementation of specialised policies, nationally tailored case by case, to effectively address
misbehaviour, wrongdoing and crime in the sport sector.

Sport remains a magnificent multicultural phenomenon which cannot’t be reduced to

homologation or the application of unbending standards - each policy should take shape
according to a nation’s specific conditions. Nonetheless a common point of origin and a shared
reference framework like this will ensure an effective international dialogue on these issues.

Within our work some prioritised elements emerge, such as the multi-stakeholder and private-
public approach, the connection with Sustainable Development GoalsSDGs, the reference to
already existing conventions and resolutions, and the synergies with regional organisations such
as African Union, ASEAN, Commonwealth, OAS, Pacific Islands, the European Union, and the
Council of Europe itself.

The cross-cutting section of the Gguidelines ultimately ensures that the approach is not only
sectorial, but well-integrated too. And in relation to the hoped-for cooperation between
international organisations, the Guidelines should prove to be a flexible and functional tool for
promoting the coherence of policies, as well as the interaction required at national level by the
different State Authorities.

These Gguidelines are simultaneously a practical ‘ready-to-use’ instrument for national

governments and a stimulus to further analyse and overcome a set of problems which will
permanently evolve but which have so far been poorly understood. We hope you find them
useful.

N.B. Signatures will be updated prior to final publication of revised version

7
Executive Summary

Under the patronage of UNESCO, the Kazan Action Plan (2017) was adopted by the Sixth
International Conference of Ministers and Senior Officials Responsible for Physical Education and
Sport (MINEPS VI). The Conference co-ordinates the efforts of sports ministries,
intergovernmental organisations, the sports movement and other stakeholders at a global level,
on issues such as sport integrity.

Action 3 of the Kazan Action Plan identifies five key policy areas. Taken together, these areas
represent the foundations for the development of a coherent policy on the protection of sport
integrity, as well as for the promotion of the fundamental United Nations Human Rights.

This paper describes in detail each of the five areas and, using aour holistic definition of sport
integrity, sets out guidelines on how to make progress against them.

The definitions, descriptions and guidelines have been compiled by a working group made up of
governmental experts, international organisations’ experts, academics and NGOs. Its work was
co-ordinated by the Enlarged Partial Agreement on Sport (EPAS) of the Council of Europe and
supported by independent consultants. The Guidelines have also been subjectwere revised in
2023 in line with the outcomes of a to a consultation issued by UNESCO to over 190
Governments worldwide under the leadership of the Bureau of the Conference of Parties to the
International Convention against Doping in Sport.

Together, they have agreed this document,These Guidelines which contains:

1) A comprehensive definition of sport integrity

2) A wide-ranging approach to sport integrity issues
3) A description of the key five policy areas:
• Preserving the rights, safety and security of athletes, spectators, workers and
other groups involved
• Preventing and addressing harassment and abuse in sport
• Fostering good governance of sport organisations
• Strengthening measures against the manipulation of sports competitions and
• Ensuring an adequate anti-doping policy framework, its implementation and
effective compliance measures.
4) The identification and presentation of cross-cutting aspects of these areas.

These guidelines, as a tool for sports ministries, are designed to be considered in all relevant
policy areas and are completed by examples of publications and good practices which can be
found online.

9
Part 1: Sport and integrity: Background and concept

Integrity of sport

“Sport has the power to change the world” – Nelson Mandela, 2000

It i’s an unfortunate fact that the more popular sport becomes across the world, the greater the
risks posed to its integrity. But while this impact is particularly visible in elite and professional
sport, where scandal hits the headlines, risk is also present at grassroots and leisure sport,
especially where commercial interests are at play.

In order to preserve the essential character of sport, cheating, violence, perversion and fraud
need to be closely monitored and sanctioned. And to be effective this requires adequate public
policies, implemented in conjunction with the sports movement itself.

Sport integrity is a multi-faceted issue and the very concept is intrinsically related to the question
of ethics in sport. But for all its complexity, integrity is an indispensable condition of play for
almost every athlete. Without integrity, sport becomes unsustainable, at the price of the
enormous potential it offers for self-fulfilment and social cohesion.

So important is integrity that the concept is firmly entrenched in variousour institutions’ formal
objectives on sport. These include:

• Article 1 of the Council of Europe’s European Sports Charter (1992): Recognising sport’s
contribution to human development, the Charter seeks: to protect and develop the moral
and ethical bases of sport, and the human dignity and safety of those involved in sport,
sportsmen and women from exploitation from political, commercial and financial gain,
and from practices that are abusive or debasing.

• Article 10 of the UNESCO International Charter of Physical Education, Physical Activity and
Sport (rev 2015): Likewise, UNESCO declares that: All forms of physical education,
physical activity and sport must be protected from abuse. Phenomena such as violence,
doping, political exploitation, corruption and manipulation of sports competitions
endanger the credibility and integrity of physical education, physical activity and sport and
undermine their educational, developmental, and health promoting functions.

• The Preamble of the UNESCO International Convention against Doping in Sport (2005)
emphasizes that doping puts at risk the ethical principles and educational values
embodied in the International Charter of Physical Education and Sport of UNESCO and in
the Olympic Charter.

Moving to a broader approach to sport integrity

10
The word integrity comes from the Latin adjective integer, meaning whole, complete, intact.
When applied to human behaviour, it reflects moral values and personal qualities such as
honesty and consistency of character. But as well as its moral dimension, physical integrity is also
of great importance, especially since sport is considered a catalyst for health and fitness.

Several organisations have provided definitions of sport integrity which focus on the honesty and
genuineness of our dealings. These definitions often also address issues related to the risks of
corruption (on and off the field of play), the equal treatment of participants and the protection of
athletes’ physical integrity from damage that can be caused by overtraining, doping, contact
sport violence, harassment, bullying and abuse. Other definitions focus on the preservation of
the social and economic value of sport and on decision-making processes and governance
practices.

References to integrity in issues related to sport are relatively recent. Traditionally these
references have mostly been associated with the risks of manipulation of sports competitions
(match-fixing, specifically linked the spectacular growth of sports betting), but also to a lesser
extent to the fight against doping.

Only recently has there been a trend to widen the scope of sport integrity to include the good
governance of sports organisations. That’s This is partly because research about what drives
match-fixing has demonstrated that a significant factor is the mismanagement of sport
organisations, and notably the lack of prevention policies to educate and protect athletes. In
addition, a multiplicity of corruption scandals has brought increased scrutiny to sports
organisations, rather than teams or players. While these organisational scandals have covered a
multitude of sins, the highest profile have related to bribery in the awarding of contracts and
competitions. Coupled with the burgeoning physical impact of mega-events, these incidents have
become increasingly problematic.

As a result, intergovernmental institutions are now raising concerns about the management of
sports organisations and are beginning to questionexamine the role of public authorities in this
area. Because of this, ‘sport integrity’ is now a broader concept, encompassing multiple stakes
and it is this principle that the Kazan Action Plan is designed to apply. By identifying five relevant
policy areas where integrity should be displayedis a focus, the plan provides an opportunity for
sport integrity to be the pre-eminent terminological reference for all ethical-related sport
matters.

In support of these five areas, our concept of integrity has three main pillars:

1. The integrity of people, including safeguards from violence and abuse and the safety and
security of people
2. The integrity of competitions, which refers to the manipulation of competition and to the
fight against doping, and
3. The integrity of organisations, which includes good governance.

11
Proposal for a holistic definition

The integrity of sport is a precondition to protect and maximise the contribution of sport to
sustainable human and social development.

For the purpose of the Kazan Action Plan, sport integrity encompasses the components of
personal, organisational and competition integrity, and thus shall reject competition
manipulation, discrimination, cheating, violence, abuse, corruption and any other crime or fraud
related to sport; promote transparency and accountability in the governance of sport; and foster
respect for internationally recognised human rights.

12
Part 2: A comprehensive approach to sport integrity issues

Introduction

"Sport is also an important enabler of sustainable development. We recognise the growing

contribution of sport to the realisation of development and peace, in its promotion of tolerance
and respect and the contributions it makes to the empowerment of women and of young people,
individuals and communities as well as to health, education and social inclusion objectives."

The United Nations' Sustainable Development Goals (SDGs)1, approved in 2015, see sport as an
important force for good. The International Olympic Committee has taken this up and
arguesagrees that "sport is a cost-effective tool for development". ,Sport can make an important
contribution stressing the contribution of sport to the following goals:

• #3 Health
• #4 Education
• #5 Gender equality and empowerment of girls and women
• #8 Decent work and economic growth
• #11 Inclusive, safe, resilient and sustainable cities and human settlements
• #12 Responsible consumption and production
• #13 Climate action
• #14 Life below water
• #15 Life on land
• #16 Peaceful and inclusive societies for sustainable development, justice for all and
effective, accountable and inclusive institutions, and
• #17 Global partnership for sustainable development.2

1
https://sustainabledevelopment.un.org/post2015/transformingourworld
2
https://www.sportanddev.org/sites/default/files/downloads/sport_contribution_to_post_2015_agenda_eng_feb.pdf

13
Delivering benefits such as those outlined in the UN’s Sustainable Development Goals requires
more than the execution of ad hoc sports projects. It also requires all operations of a sport
organisation to at least observe the imperative, ‘Do no harm’.

This means that clubs, federations and associations, whether at local, national or international
level, need to be "effective, accountable and transparent institutions" as laid down in SDG #16,
allowing for the participation of their stakeholders. Integrity, as defined in these guidelines, is key
to the future role of sport all over the world and it is up to governments - and to sports ministers
- to support all who offer sport to work towards it.

This approach is mirrored elsewhere too. It is, for example, in line with the Berlin Declaration
adopted by MINEPS V in 20133, which is aimed at "strengthening the educational, cultural and
social dimensions of sport and physical education and … developing an international sport and
physical education policy which fosters peace and understanding between peoples and which
safeguards human rights in the world of sport by creating access to sport for all, improving
physical education, developing new standards for mega and major sport events and preserving
the integrity of sport".

Central to the Kazan Action Plan (KAP), therefore, is a commitment to develop and implement
policy that strengthens alignment between sport and the SDGs. The plan recognises “the full
potential of physical education, physical activity and sport to contribute significantly to the
achievement of Sustainable Development Goals” and stresses that this objective can only be
realised if a “broad range of public authorities, sports and educational organisations and other
stakeholders are mobilised”. This responds to growing policy frameworks and research that show
that intentionally-designed and well-delivered sport-based interventions can create valuable
human and social development outcomes4 – an objective that all policy-makers can agree with.

3
http://www.mineps2013.de/fileadmin/Dokumente/pdf/MINEPS%20V%20-
%20%20Declaration%20of%20Berlin%20%28Original%20English%20Final%29.pdf
4
Enhancing the Contribution of Sport to the Sustainable Development Goals, available at:
https://thecommonwealth.org/sites/default/files/inline/EnhancingtheContributionofSporttotheSustainableDevelopmen
tGoals.pdf

14
Central to the Kazan Action Plan is the MINEPS Sport Policy Follow-up Framework, a tool to assist
with policy convergence, promote international co-operation, and provide a framework for
capacity-building efforts of governmental authorities and sport organisations. The Framework
identifies nine SDGs and 36 associated targets where sport-based approaches could make an
effective and cost-efficient contribution.

• #3 Health
• #4 Education
• #5 Gender
• #8 Decent work and economic growth
• #10 Equality
• #11 Sustainable cities and communities
• #12 Sustainable consumption
• #13 Combating climate change
• #16 Peace, justice and strong institutions

The SDGs have a substantial focus on issues of governance and integrity and are grounded in the
Uuniversal Ddeclaration of Hhuman Rrights and their its associated conventions5. The
interconnected and indivisible nature of each of the 17 goals is also underscored emphasising, for
example, that peace, justice and strong institutions (SDG16) fundamentally impact on the
achievements of goals related to health (SDG3), education (SDG4) and economic development
(SDG8). These underpinning principles at the highest level of global policy-making reinforce the
importance of coherence between sport integrity, sport and human rights and the contribution
of sport to the SDGs.

Responding to this emphasis, the Kazan Action Plan recognises that “the effective protection and
promotion of the integrity of sport are the preconditions for preserving its developmental,
educational and health-promoting functions” - in other words, the contribution of sport to the
SDGs.

On this basis, it’s worth noting that theThe following SDG targets relating to protecting the
integrity of sport have been specifically mentioned in the Kazan Action Plan under Main Policy
Area 3:

• 5.2 - Eliminate all forms of violence against all women and girls in the public and private
spheres, including trafficking and sexual and other types of exploitation
• 5.5 - Ensure women’s full and effective participation and equal opportunities for
leadership at all levels of decision-making in political, economic and public life
• 8.7 - Take immediate and effective measures to eradicate forced labour, end modern
slavery and human trafficking and secure the prohibition and elimination of the worst

5
Transforming our world: the 2030 Agenda for Sustainable Development, 37

15
 forms of child labour, including recruitment and use of child soldiers, and by 2025 end
child labour in all its forms
• 16.2 - End abuse, exploitation, trafficking and all forms of violence against and torture of
children
• 16.3 - Promote the rule of law at the national and international levels and ensure equal
access to justice for all
• 16.4 - By 2030, significantly reduce illicit financial and arms flows, strengthen the recovery
and return of stolen assets and combat all forms of organised crime
• 16.5 - Substantially reduce corruption and bribery in all their forms
• 16.6 - Develop effective, accountable and transparent institutions at all levels.

Sharing responsibility for sport integrity outside of the autonomous sports organisations

According to the present guidelines,S sport integrity relies on the ethical conduct of athletes,
officials and participants in sport at all levels and relies on transparent, protective and
accountable governing bodies and administrators. Whether it operates at a professional or
amateur level, an organised sport driven by integrity must reject manipulation, discrimination,
cheating, violence, abuse and corruption and commit itself to fundamental internationally-
recognised human rights. Sport integrity is displayed when it enables sport at all levels to engage
participants on a path towards fulfilment, social inclusion, healthy lifestyle and ethical behaviour.

Whether it is’s babies learning to swim, football for girls and boys, athletes training for the
Paralympics, nurturing traditional games or getting elderly people active, the risks posed to
integrity can sometimes outweigh the advantages of active involvement. In addition, gaps in
integrity can affect the reputation of sports organisations and lead to the loss of financial and
personal resources that may threaten the sustainability of sport.

Sport organisations, as an important – and in many countries the biggest – part of civil society,
have a key role to play in addressing these sports integrity issues. And to be aware of these risks
and take the right measures for prevention and remedy, a sports organisation needs to listen to
its own members – as well as involve external stakeholders. SBut it’s also important for sports
organisations mustto understand that they have no exclusive competence on sport integrity
issues, and that wider society may have much to contribute. That’s This is why sport needs a
broader definition of integrity, responsibility for which should not rest only on the shoulders of
sports organisations.

The sports movement itself recognises that its autonomy relies wholly on being able to display
good governance6. As the IOC itself recognises:

6
https://stillmed.olympic.org/media/Document%20Library/OlympicOrg/IOC/Who-We-Are/Commissions/Ethics/Good-
Governance/EN-Basic-Universal-Principles-of-Good-Governance-2011.pdf#_ga=2.84064665.1219517887.1567150039-
2114723716.1562586449

16
“Good governance and autonomy are strongly linked; they are two sides of the same coin.
Organisations belonging to the Olympic Movement can rely on the Olympic Charter
(Fundamental Principles of Olympism, no. 5) when claiming their autonomy. But the strongest
token to ensure the autonomy of our Movement and its member organisations is the application
of appropriate standards of good governance” (Source: Olympic Agenda 2020: Context and
Background).

Governments should therefore not turn a blind eye tocannot overlook sport integrity issues by
usingon the basis of thea concept of ‘autonomy of sport’ as an excuse, because if basic
governance requirements are not fulfilled - and sport integrity is part of those requirements –
autonomy cannot be guaranteed. When the UN General Assembly passed a resolution in 2014
that referred to “autonomy”7, IOC President Dr Thomas Bach went on to refine the term in this
context by referring to it as "responsible autonomy"8.

So respectingRespecting the autonomy of sport doesn’t does not therefore mean that
governments have no role to play – on the contraryin the area of sport integrity. On the contrary,
they have a fundamental contribution to make..

By setting a clear legal framework and making prevention concepts as well as templates for
internal regulations available, public authorities can preserve the integrity and autonomy of
sports organisations and help them to achieve the potential of sport to do good.

The objective of these Gguidelines is to provide governmental authorities in charge of sport with
references, background and methodologies to develop such sports integrity policies.

Sport integrity - Existing obligations

The five policy areas covered by the Kazan Action Plan’s approach to sports integrity are:

1. Preserving the rights, safety and security of athletes, spectators, workers and other
groups involved
2. Preventing and addressing harassment and abuse in sport
3. Fostering good governance of sport organisations
4. Strengthening measures against the manipulation of sports competitions
5. Ensuring an adequate anti-doping policy framework, its implementation and effective
compliance measures.

7
https://www.un.org/ga/search/view_doc.asp?symbol=A/69/L.5
8
https://www.olympic.org/news/historic-milestone-united-nations-recognises-autonomy-of-sport; see as well the Communication of
the Commission of the European Union on the European Dimension in Sport, 18.1.2011, referring to "Good Governance as a
condition for the autonomy of sport" and accepting "autonomy within the limits of the law, democracy, transparency and
accountability in decision-making, and inclusiveness in the representation of interested stakeholders." - https://eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52011DC0012&from=EN

17
These areas are all – albeit in different ways - addressed already by mandatory international
conventions, treaties, and sport regulations. This section gives a short overview of that
international regulatory landscape.

The UN Convention against Corruption (UNCAC – see especially Article 12 on Private Sector)9, the
International Labour Organization's (ILO) Standards10 and the Universal Declaration of Human
Rights11, completed by a wide range of specific UN Conventions (e.g. Convention on the Right of
the Child12, and the Convention on the Elimination of All Forms of Discrimination against
Women13 and others14) are legally-binding standards that are applicable in all sectors of activity –
including sport. These UN conventions are complemented by other multilateral treaties
developed by regional organisations15. According to these commitments, states are obliged to
implement (and maintain) the rule of law in their territory, to protect their citizens against any
kind of discrimination and abuse and to hold state entities and the private sector to account. This
includes sport organised by public authorities themselves (e.g. in schools, universities, the army,
police etc), by sports organisations (e.g. major sports events like continental or world
championships, Olympic and Paralympic Games) or by corporate sports entities.

With regard to human rights, the UN Guiding Principles for Business and Human Rights (UNGP)16
have specified the states' "existing obligations to respect, protect and fulfil human rights and
fundamental freedoms"17 by emphasising that states must require "business enterprises to
respect human rights"18. This applies to sports organisations too and organisations including
that’s why the IOC, the Commonwealth Games Federation and Fédération Internationale de
Football Associations (FIFA) all formally acknowledge the UNGP as a leading guide in fulfilling
their human rights obligations.

General international standards and international sports regulations like this are complemented
by specific instruments. On anti-doping, the World Anti-Doping Code, which brings consistency to
the anti-doping rules and regulations of the key sports organisations, relies Governments have
indicated their firm support for the establishment of an effective and robust anti-doping
framework by way of two key on international conventions19 which both commit and enable
states to playing their part in the fight against doping. Moreover, within the World Anti-Doping
Agency, both governmental authorities and sports organisations co-ordinate the anti-doping

9
file:///U:/TISPi/Internationales/IPACS/Kazan/Kazan%20draft/UNCAC.pdf
10
https://www.ilo.org/global/standards/lang--en/index.htm; https://www.ilo.org/global/standards/introduction-to-international-
labour-standards/conventions-and-recommendations/lang--en/index.htm
11
https://www.un.org/en/universal-declaration-human-rights/index.html
12
https://www.unicef.org/child-rights-convention
13 13
https://www.ohchr.org/Documents/ProfessionalInterest/cedaw.pdf
14
For an overview of the UN relevant conventions please see list of Core International Human Rights Instruments and their
monitoring bodies https://ohchr.org/EN/ProfessionalInterest/Pages/CoreInstruments.aspx
15
Relevant Treaties and monitoring mechanisms from the Council of Europe are presented here (link).
16
https://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf
17
UNGP General Principles (a)
18
UNGP I.A.2 and 3
19
The UNESCO International Convention against Doping in Sport (http://www.unesco.org/new/en/social-and-human-
sciences/themes/anti-doping/international-convention-against-doping-in-sport/) and the Council of Europe Anti-doping Convention
(https://www.coe.int/en/web/conventions/full-list/-/conventions/treaty/135)

18
policies. The effectiveness of the World Anti-Doping Code – developed and monitored by the
World Anti-Doping Agency, which brings consistency to the anti-doping rules and regulations of
the key sports organisations - is wholly dependent on these Conventions being implemented by
Governments worldwide.

With respect to measures against the manipulation of sport competitions, the Convention on the
Manipulation of Sports Competitions (the Macolin Convention20) entered into force on 1
September 2019 and is mirrored by the Olympic Movement Code on the Prevention of the
Manipulation of Competitions.21 Although policies against manipulating sports competitions are
not as advanced and widespread as anti-doping policies, there is already broad agreement on a
coherent approach. which is backed by solid standards.

On the issue of safety of athletes and spectators, it is worth noting that the European Convention
on Spectator Violence and Misbehaviour at Sports Events and in particular at Football Matches,22
is being replaced by the Council of Europe Convention on an Integrated Safety, Security and
Service Approach at Football Matches and Other Sports Events.23

In addition to international conventions and sports regulations, some sport integrity issues are
sometimes addressed directly by bodies in charge of the monitoring of more general
international standards. They formulate recommendations directed to governments on how to
better implement existing standards. As an example, the Special Rapporteur on the Sale and
sexual exploitation of children, including child prostitution, child pornography and other child
sexual abuse material recently issued a report24 which includes a study on the sale and sexual
exploitation of children in the context of sports.

These politically-based international obligations are completed with regards to sport regulations
by the policy statements and frameworks of sports organisations themselves. For example, the
IOC offers its Basic Universal Principles of Good Governance of the Olympic and Sports
Movement25 and WADA theits Ccode26, while on the safeguarding of children, the IOC and FIFA
have both launched toolkits.

The relationship between risk and integrity

20
https://rm.coe.int/CoERMPublicCommonSearchServices/DisplayDCTMContent?documentId=09000016801cdd7e
2121
https://stillmed.olympic.org/Documents/Commissions_PDFfiles/Ethics/olympic_movement_code_on_the_prevention_of_the_mani
pulation_of_competitions-2015-en.pdf
22
https://www.coe.int/en/web/conventions/full-list/-/conventions/treaty/120
23
https://www.coe.int/en/web/conventions/full-list/-/conventions/treaty/218
24
https://documents-dds-ny.un.org/doc/UNDOC/GEN/G18/446/93/PDF/G1844693.pdf?OpenElement
25
https://stillmed.olympic.org/media/Document%20Library/OlympicOrg/IOC/Who-We-Are/Commissions/Ethics/Good-
Governance/EN-Basic-Universal-Principles-of-Good-Governance-2011.pdf#_ga=2.237647047.637948839.1566305080-
905398718.1561990971
26
https://www.wada-ama.org/en/what-we-do/world-anti-doping-
codehttps://stillmed.olympic.org/media/Document%20Library/OlympicOrg/IOC/Who-We-Are/Commissions/Ethics/Good-
Governance/EN-Basic-Universal-Principles-of-Good-Governance-2011.pdf#_ga=2.237647047.637948839.1566305080-
905398718.1561990971

19
As we have reported, there is a broad background of standards and regulations relevant to sport
integrity. But to fully protect integrity, we also need a clear view of the specific risks to it and the
measures which can be taken to mitigate them. Because no system is fool-proof, sport also
requires systems to remedy any damage and to sanction the behaviour that causes it.

In the area of doping and with the global support of governments as expressed through the
UNESCO and Council of Europe Conventions concerning doping, sports organisations have taken
such a path by developing a unique framework that applies all over the world. But similar global
systems are not yet fully applied to other threats to sport integrity.

To picture how good governance can work across sport, it can help to think of how you might
prepare for a football match for the first time.

First of all, you need a pitch and the rules of the game – how to play football. This is comparable
to establishing the structure of the sport.

Secondly, you need to identify the risks that endanger a decent game – what things can happen
that damage the game or lead, for example, to injuries? Events like fouls, handballs or trips fall
into this category. Now that you know these risks, what do you need to manage them?27 The
rules to avoid foul play have to be defined. This is equivalent to setting the frameworks for
integrity.

And then, of course, the participants have to know these rules, so you need to educate them
accordingly. This is the same as making sure that everyone involved in your sport or organisation
understands their role and responsibilities with regard to integrity.

But even then, there is no guarantee that the players will stick to the rules and will play fair (i.e.
with integrity). On the contrary - the more competitive the situation is, the bigger the risk that
players will try everything to stop an opponent, to get hold of the ball. That is why, fourthly, you
need a referee to make sure that the rules are being complied with.

The referee has a whistle, a yellow and a red card – to signal that something is going wrong. This
is equivalent to your organisation having people responsible for ensuring the rules and
frameworks are observed and that people are sanctioned when they do not do so.

If the referee her or himself does not act with integrity and use the whistle consistently from the
very beginning, i.e. making clear that she/he is in charge of the match and will require that the
players avoid making fouls, she/he will not be taken seriously and in the end will lose control of
the match. Consequently, addressing any deviation from the rules is key to ensuring fairness on
the pitch. The same applies off the pitch. Rules around integrity need to be applied consistently
and fairly for them to be respected universally.

27
https://ppp-certification.com/ppp-certification-guide/52-defining-risk-risk-management-cycle36

20
Effectively transferring this approach to sport integrity requires a thorough implementation of
general good governance principles, such as democracy with checks and balances, transparency,
and accountability - all accompanied by their proper application.

IWhat’s more, integrity strategies undertaken by sports organisations will only be effective if
leadership teams set the right example. A president not sticking to the rules or a CEO misusing
power or money will have no authority to ensure integrity is applied more widely. Sports
integrity and good governance are closely interlinked: on the one hand, addressing sport integrity
issues implies securing good governance, and on the other, implementing good governance in
sport requires addressing sport integrity issues.

Assessing and dealing with risk

Whatever the starting point, an analysis is needed to identify what risks a sport is facing. At the
organisational level, the degree of risk and the corresponding mitigating measures will depend on
the size, the budget, the complexity of contracts and transactions, the national context and the
legal environment, but also on the specific sport and the composition of its membership or
athletes.

For example:

• Some sports are more at risk of accidents

• Sports with many very young athletes face an increased risk of sexual harassment physical
and mental abuse
• In equestrian sport, animal welfare is an issue
• Sports where doping has a hugecan have an immediate impact on performance – e.g. on
endurance or muscle power - face a bigger risk of prohibited substances being used
• Sports with which attract a high amount volume of betting are often pronemore
susceptible to attempted or actual to manipulation.

Human rights deficiencies (for example, a country with that provides no or limited access to sport
for girls and women) can be a challenge for a national sport organisation when fulfilling its
obligations under the Olympic Charter. Another risk may be to workers’ rights28 when a sports
event requires the construction of new facilities. These are examples of cases where, alongside
prevention measures, access to effective remedies is a key part of acting in line with the UNGP.

Once listed, these risks have to be assessed with regard to severity and likelihood29. The
classification is usually supported by a risk matrix, like the one below.

28
https://egyptindependent.com/tokyo-olympic-construction-race-raises-worker-safety-questions/
29
https://www.liquidplanner.com/blog/9-steps-risk-management-process/

21
According to the outcomes of this risk assessment, a sport organisation (or organising committee
for a major sport event) should then develop prevention measures, addressing the most severe
risks as a priority.

These measures can be of a structural nature (for example, using equipment which diminishes
the risk of accidents or making a change to a competition time to avoid the impact of the heat) or
comprise regulations (on conflicts of interest, anti-bribery rules, or a policy on safeguarding
children, for example).

They should be accompanied by controls, a reporting mechanism and a disciplinary system,

including procedures and policies, to ensure that information on any problem occurring is
gathered as early as possible and that breaches of the rules are investigated and sanctioned
appropriately.

The role of the state authorities

PAs we have discussed, protecting sport integrity requires a multi-stakeholder approach, and
public bodies and policy-makers have a significant role to play.

The jurisdiction and politics in a country set the stage for sport. For example, a constitution may
guarantee freedom of association; private law provides the legal framework for an organisation;
the education system shapes sport in schools and universities; and the administration of justice
secures the rule of law, including access to effective remedy.

Yet as experience has shown such a framework is not, on its own, sufficient to ensure the
integrity of sport. A strategic approach to addressing sport integrity issues has to be supported by

22
those responsible for sport, especially the sport ministers. This task can itself be seen as a specific
kind of risk management. In undertaking it, ministers need to ask themselves:

• What are the risks to sport integrity in the country?

• What measures around our legal framework, structure, policies, financial support and
input on content can address them?

The first step should be to analyse the country's legal and political framework, including
international commitments – in the area of anti-doping, (for example, the UNESCO International
Convention against Doping in Sport), and its implementation. The Conference of Parties for the
UNESCO Convention recognises that this planning phase is crucial and in that regard has
approved both Operational Guidelines for implementation, and a Model Strategic Framework is
being developed, beingcomprising a number of planning documents that public authorities can
use in relation to key parts of the Convention.

Any deficiencies with a negative impact on the practice and organisation of sport, whether they
lie in the education system, a private non-for-profit or a commercial institution, should be
addressed. This should be the case whether those deficiencies lie within the direct orbit of a
sports ministry or outside of its formal responsibilities.

The second step should be to ensure that general policies which are also relevant to addressing
sport integrity risks (e.g. anti-corruption policies, child safeguarding policies, etc.) are applicable
and implemented in the sports sector. Specialised policies stemming from international
commitments (e.g. the Conventions concerning on anti-doping, manipulation of sports
competitions, etc.) should also be fulfilled. International regulations norms and standards have to
be transposed to the national level and appropriate resources should must be allocated to these
policies in terms of the right skills, finance, structures and personnel.

The third step is to raise awareness within the sport sector of the risks and the necessity for a
sport integrity strategy covering all the relevant policy areas. While the framework on anti-doping
has been clearly set by international regulations norms for a long time, risks and approaches to
address other policy areas are not yet understood in detail by many sport officials at national
level. The allocation of governmental resources to sports organisations should be linked to
realistic goals, support and co-operation (e.g. education on risk management, good practice
examples, networking with the competent authorities). They should also be subject to
compliance with good governance.

The most important role for sport ministers is to lead from the top themselves, that is by setting
an example of integrity. This is the sine qua non condition that will enable sport to keep its
promises, succinctly outlined by Nelson Mandela:

“Sport can create hope where once there was only despair. It is more powerful than
governments in breaking down racial barriers. It laughs in the face of all types of discrimination
that goes out into the world, spreading help, inspiration, and hope.”

23
Part 3: Integrity without boundaries – Elements which cross-cut the five policy areas

In this section, we examine a number of elements which cross-cut our five policy areas. All of
these elementsThe elements discussed below intersect two or more areas and, as such, provide
meaningful contributions to the goal of sport integrity.

They are:

• Multi-stakeholder initiatives
• Whistle-blowers and a free media
• The protection of human rights
• Education, prevention and awareness-raising
• Monitoring implementation policies and
• Gender and youth mainstreaming.

G) Multi-stakeholder initiatives

Introduction

Sport is one of the biggest civic movements in many countries all over the world. And if one
assumes that tThe sport movement represents all facets of society, it is no wonder that sport and
faces similar integrity challenges to the other spheres of our lives.

Where these challenges arise, they should be addressed with comprehensive policies which
encompass governance, prevention and sanction aid to victims. Yet this is complex. For example,
education may require the services of clubs and schools. The functions of detection and
punishment may cover disciplinary infringement, but also breach of administrative law or even
criminal offences. Meanwhile, aid to victim may involve protection measures and social care.

As a result, it’s clear that noNo single sports organisation and no single public authority can
control all the actions required to address these issues. This is why it’s so important thatFor this
reason, international conventions on sport integrity issues rely on multi-stakeholder co-
ordination. So it’s good news that coCo-operation and co-ordination are well-established
principles in the policies that guide our an understanding of sport integrity.

For example, in relation to the UNESCO International Convention Against Doping in Sport, by
committing themselves to the UNESCO’s International Convention Against Doping in
SportConvention, stipulates that theover 190 States Parties have undertaken towill both
domestically and internationally take appropriate measures which are consistent with the
principles of the World Anti-Doping Code. It says, that they should “encourage all forms of
international co-operation aimed at protecting athletes, and ethics in sport, and at sharing the
results of research, and foster international co-operation between States Parties and leading

25
organisations in the fight against doping in sport, in particular with the World Anti-Doping
Agencies (WADA)” (Article. 3 c).

It adds that “States Parties shall ensure the application of the present Convention, notably
through domestic co-ordination. To meet their obligations under this Convention, states Parties
may rely on anti-doping organisations as well as sports authorities and organisations” (Article. 7).
In implementing the Convention, many States Parties have established a National Anti-Doping
Organisation (NADO) specifically for this purposeThis is currently implemented via national
compliance platforms that are set up in more than 90 countries.

This multi-agency approach is mirrored in Article 3 of the Council of Europe Anti-Doping

Convention (1989). It states that “The Parties shall co-ordinate the policies and actions of their
government departments and other public agencies concerned with combating doping in sport”.
Meanwhile Article 3.2. says “They shall ensure that there is practical application of this
convention, and in particular that the requirements under Article 7 (Co-operation with sports
organisations on measures to be taken by them) are met, by entrusting where appropriate, the
implementation of some provisions of this Convention to a designated governmental or non-
governmental sports authority or to a sports organisation.”

Given the complexity of the problem, it is natural that national anti-doping agencies work
together with the police, customs, law enforcement and public health authorities, as well as with
the sport movement. In many cases, as a practical tool, MOUs between the anti-doping agencies
and police and customs are employed.

In the Council of Europe Convention on an Integrated Safety, Security and Service approach at
Football Matches and other Sport Events (2016), arrangements go even further. Under Article 4,
at the national and local levels, it says that member states shall ensure that:

• “National and local co-ordination arrangements are established for the purpose of
developing and implementing a multi-agency integrated approach to safety, security and
service.
• Co-ordination arrangements are established to identify, analyse and evaluate the risks
pertaining to safety, security and services, and to allow the sharing of updated
information on risk assessment.
• The co-ordination arrangements involve all key public and private agencies responsible
for safety, security and service matters connected with the event, both inside and outside
of the venue where the event is taking place.
• The co-ordination arrangements take full account of the safety, security and service
principles set out in this Convention and that national and local strategies are developed,
regularly evaluated and refined in the light of national and international experience and
good practices.
• National legal, regulatory or administrative frameworks clarify the respective roles and
responsibilities of the relevant agencies and that these roles are complementary,

26
 consistent with an integrated approach and widely understood at strategic and
operational levels.”

In addition, the latest open convention to enter into force (the Council of Europe Convention on
the Manipulation of Sport Competitions) states that:

“Each Party shall co-ordinate the policies and action of all the public authorities concerned with
the fight against the manipulation of sports competitions.

Each Party, within its jurisdiction, shall encourage sports organisations, competition organisers
and sports betting operators to co-operate in the fight against the manipulation of sports
competitions and, where appropriate, entrust them to implement the relevant provisions of this
Convention.”

These measures demonstrate that a developed and co-operative multi-stakeholder integrated

approach to safety, security and service at national and local level is the policy-maker’s favoured
tool for achieving integrity.

Co-ordination among the relevant public authorities

In this same spirit, the development of any sport integrity policy should strive to identify the
relevant actors who may contribute to fulfilling any functions in the development and the
implementation of the policy. Leaving stakeholders out of this process can flaw the outcomes.

As a starting point, the following outline reflects an example of a mapping exercise to identify the
relevant authorities for each policy area. A similar exercise should be conducted in every country
to identify the relevant tagholders, tailored to the institutional and legal setting of the country.

Policy Preserving Preventing Fostering Strengthening Ensuring an

areas the rights, and good measures adequate anti-
safety and addressing governance against the doping policy
security of harassment of sport manipulation framework, its
athletes, and abuse in organisations of sports implementation
spectators, sport competitions and effective
workers and compliance
other measures
groups
involved
Ministry of
X X X X X
Sports
Sport
integrity X X X X X
agency

27
Anti-
doping X X
agency
Police X X X X

Prosecutor X X X X

Customs X X

Ministry of
X
health
Ministry of
X
labour
Child
protection X
authorities
Betting
X
regulator

Depending on the organisation and institutional setting of the state services, some countries may
also include their ministries of justice, internal affairs and education.

Co-ordination with other stakeholders

While the co-ordination of public authorities is a first step in achieving a successful sport integrity
strategy, it is also necessary to include civic organisations – including sports bodies – in the
process. They can have much to add – take this example of a sports organisation working with
other bodies in the areas of anti-doping and anti-manipulation.

The International Olympic Committee (IOC) was the first sports organisation to set up an
independent Ethics Commission in 1999 in order to safeguard the ethical principles of the
Olympic Movement.

These principles are set out in the Code of Ethics and its Implementing Provisions and, in 1999,
the IOC organised the first World Conference on Doping in Sport in Lausanne. The establishment
of the World Anti-Doping Agency (WADA) was a direct result of this conference. Today, WADA is
funded equally by the Olympic Movement and world governments, and its Foundation Board and
Executive Committee are also composed of representatives drawn equally from both sides.

Sport was officially recognised as an “important enabler” of sustainable development and

included in the United Nations 2030 Agenda in 2015. In developing its anti-doping capabilities,
the IOC has worked in close co-operation with the United Nations Office of Drug Control
(UNODC).

28
For example, the IOC has published a study with UNODC (the UNODC-IOC Study Criminal Law
Provisions on the Prosecution of the Manipulation of Competitions) in order to assist countries in
establishing effective legislation to prosecute those involved in competition manipulation. The
IOC also supports the implementation of the Council of Europe Convention on the Manipulation
of Sports Competitions among its member states. As part of this, it works in partnership with
INTERPOL in the Global Integrity in Sport Capacity-Building Programme to implement a joint
strategy focusing on the prevention and investigation of competition manipulation and related
crimes in sport.

In fact, in early 2010, a strong impetus from the IOC and UEFA Presidents prompted the Council
of Europe to start drafting the first international legal instrument against the manipulation of
sports competitions. In addition, FIFA has supported and actively promoted the entry into force
of the Macolin Convention and has concluded memoranda of understanding dedicated to the
protection of sport integrity with the IOC, as well as various betting operators and other service
providers in the betting industry. This topic also features prominently among the collaboration
areas under the Council of Europe-FIFA memorandum of understanding, the African Union-FIFA-
Confederation of African Football MoU and the recently concluded Association of Southeast
Asian Nations (ASEAN)-FIFA MoU.

These are just a few examples of how international sport is leading the way with multi-
stakeholder initiatives at international level. Many other international federations participate in
co-operation activities independently, as well as through the IOC.

At this stage, the role of athletes in integrity initiatives should be underlined - both at the
international and national level. The involvement of athlete unions and associations at different
stages of policy-making, implementation and monitoring will help to ensure that the measures
developed are legitimate, fair, proportionate and effective.

At a national level, the sports movement needs to co-operate with many other stakeholders too
to ensure a systemic approach within a national strategic framework addressing targets. As we
mention later on, NGOs – especially those involved with children, human rights and anti-
corruption – all have a role to play.

A recent example of this kind of national co-operation is the relationship between the Family
Federation of Finland, Finnish sport and the Finnish Centre for Integrity in Sports. Their ‘You are
not alone’ project is a joint venture for all children, youths and their relatives who have faced
discrimination, violence and bullying. It’s alsoIt is the first support activity in Finland focused on
helping those who have been sexually abused, harassed and bullied. The project offers hotline
and chat services, and a chance to talk confidentially with an expert. It’s also a goodIt is an
excellent example of using the best possible expertise in what is an important and difficult area.

In the field of anti-doping, the Conference of Parties of the International Convention Against
Doping in Sport promotes the establishment of national ‘compliance platforms’ on the

29
implementation of the convention, gathering all the relevant stakeholders.in line with Article. 7
of and as decided by the Conference of Parties to the International Convention against Doping in
Sport, States Parties have also established National Compliance Platforms involving key
stakeholders (Ministries, NADO, sport movement, customs, medical and pharmaceutical sectors,
etc.) to ensure domestic coordination. These National Compliance Platforms are a means by
which public authorities coordinate the measures they take to implement their commitments
made pursuant to the Convention, and to report on and evaluate the effectiveness of those
measures. In 2023, the global network gathersencompassed over 130 such Platforms.

Recent trends

Multi-stakeholder initiatives can be defined as voluntary partnerships between governments, civil

society, and sometimes the private sector.

Against this background, twoTwo promising practices have recently emerged that may describe
trends for the development of multi-stakeholder arrangements:

• National platforms, often established by law, which require the sharing of information,
and the analysis and co-ordination of cases with law enforcement and justice
• Multi-task initiatives - The identification of a single agency entrusted with the co-
ordination of policy implementation on multiple sport integrity issues.

We explore both practices in more detail below.

National platforms – Multi-stakeholder exemplars

A model of a multi-stakeholder initiative is a national platform as described in Article 13 (and 12)

of the recent Macolin Convention. It describes a national platform as something which:

• Serves as an information hub, co-ordinating the fight against the manipulation of sports
competitions
• Receives, centralises and analyses information on irregular and suspicious bets placed on
sports competitions and where appropriate, issues alerts
• Transmits information on possible infringements of laws and sports regulations to public
authorities or sports organisations and/or sports betting operators
• Co-operates with all organisations and relevant authorities at national and international
levels, including the national platforms of other states.

To be able to fulfil its obligations and tasks, a national platform could consist of:

1) Public authorities at large (ministries of sport, law enforcement, betting regulatory

bodies)
2) Sports at large (NOC, Paralympic Committee, representatives of national federations,
athletes/players), and

30
 3) Licensed betting operators.

The national federations may vary, but football is represented almost without exception, tennis
and basketball in many cases, and other sports only in those countries where they are a popular
sport. Athletes/players are not represented in all the existing platforms, but due consideration
should be given to the idea that participants are not part of the problem but part of the solution.
This lesson should be taken from anti-doping activities, where the lack of involvement of athletes
has sometimes led to significant difficulty.

The Macolin Convention came into force in the autumn of 2019. Six signatories have already
ratified the Convention, with 36 having signed it. But before its inception, in July 2016, the
Council of Europe took the initiative of bringing together the co-ordinators of officially
established national platforms to create an operational network called the Group of Copenhagen.

Since its creation, the network has met eight times and now represents 29 national platforms,
three of them from outside Europe (in Canada, Morocco and United States of America). Together
they have worked on:

• The elaboration of studies and compilations of good practice

• Providing practical support to existing national platforms to consolidate and further
improve their systems
• Assisting countries in the creation of a new national platform
• Supporting capacity-building initiatives for the benefit of institutional actors and
professionals at national level
• Monitoring several major sports events as part of the MoU signed between the Council of
Europe and FIFA - including the 2018 FIFA World Cup in Russia.

During the FIFA Women’s World Cup in France in 2019, and in co-operation with the French
National Platform, the Group of Copenhagen played a role in the tournament’s Integrity Task
Force, which was specifically set up to monitor the competition and support FIFA in addressing
any integrity-related concerns.

The Group’s current aim is to produce a relevant first set of guidelines for the National Platforms.

The Conference of Parties for the UNESCO Convention Against Doping in Sport has promoted the
concept of States Parties establishing National Compliance Platforms, these being a means by
which public authorities may coordinate the measures they take to implement their
commitments made pursuant to the Convention, and to report on and evaluate the effectiveness
of those measures.

Multi-task initiatives

While the Convention covers a wide range of objects, there are also other forms of unethical
behaviour which must be tackled to protect sport integrity.

31
As a result, there are already a few examples of multi-stakeholder initiatives which have turned
into multi-task initiatives.

For example, as part of work being undertaken within the context of developing its National
Sport Plan, the Australian government also commissioned a review of the country’s sport
integrity arrangements.

The Wood Review was published in 2018 and some of the key findings were as follows:

• Threats to sport integrity in Australia are not limited to doping and competition
manipulation. Equally important are harassment, bullying and discrimination; child
protection; health and safety issues; accreditation of athlete support personnel;
regulation and supply of performance and image enhancing drugs, including in sporting
and dietary supplements; gender issues; and corruption of new and emerging sports
without identifiable controlling bodies (for instance e-sports).
• Current and future foreseeable sport integrity threats cannot be effectively addressed
without a formal, national capability dedicated to co-ordinating the collection, analysis
and dissemination of information and intelligence.
• A recalibrated and cohesive national response wais required, featuring improved
structures and systems to aid collaboration and partnership across all relevant
stakeholders including international counterparts.

The Wood Review recommended that the Government establish a national sport integrity agency
that could cohesively draw together and develop existing sport integrity capabilities, knowledge
and expertise.

In February 2019, the Government announced its response to the Wood Review, and among a
string of reforms targeting doping, match-fixing and illegal betting, agreed to establish a single
sport integrity agency. In April 2019, it introduced legislation to establish Sport Integrity Australia.
The organisation will implement Australia´s international obligations under both the UNESCO
International Convention against Doping in Sport and, once in force and binding on Australia, the
Council of Europe’s Convention on the Manipulation of Sports Competitions (the Macolin
Convention).

The fundamental issue for Australia now is what it refers to as a “continuum of connected sport
integrity threats”, from serious crime and member abuse issues through doping, other forms of
unethical behaviour and discrimination and harassment in sport. Their logic, as senior
Government official Andrew Godwin states, “is that connected threats need a connected
response if we are to be successful in confronting them”.

Another example of this kind of multi-task approach is demonstrated by the Finnish Centre for
Integrity in Sports (FINCIS). The roots of its foundation were planted by the Council of Europe

32
Convention on the Manipulation of Sports Competitions and the Finnish Government’s signature
of it in September 2014.

However, like in Australia, the work had started beforehand. In 2011, after a review by Judge
Lauri Tarasti and a governmental Working Group, the Ministry of Education and Culture
(responsible for sport) established an Advisory Board for Ethics in Sports, where other, non-
sporting NGOs are represented - namely Human Rights Finland and Save the Children Finland.

Its sub-committee functions as the National Platform which co-ordinates, for example, the fight
against the manipulation of sports competitions. The task of being the National Platform’s
secretariat was entrusted to FINCIS.

FINCIS was founded in 2016, following the former Finnish Antidoping Agency (FINADA), and has
the task of implementing the two Council of Europe conventions (Manipulation of Sports
Competitions and Integrated Safety, Security and Service Approach at Football Matches and
Other Sports Events), alongside the UNESCO and Council of Europe Anti-Doping Conventions. A
multi-stakeholder approach was in place from the beginning, in order to involve relevant public
authorities, sport at large (including the athletes) and licensed betting operators.

In the summer of 2016, it took only a few weeks to realise that, besides being a multi-stakeholder
and multi-task organisation, FINCIS needed to strengthen ethics in sport. Even during the short
time it has been in existence, this independent, professional organisation has published a report
on equality and reviewed several cases of harassment and sexual abuse, on top of its activities in
anti-doping and competition manipulation. It sees strengthening ethics in sport as being key to
the successful implementation of the international conventions.

Overall, Finland follows a coordinated approach to governance and implementation of ethical

issues in sport through the use of legislation and the creation of supportive structures. These
include the Ministerial Advisory Board for Sport Ethics, this being a coordinating and cooperation-
facilitating body between different administrative branches and sports bodies (the Advisory
Board sub-committee acts as the national platform referred in the Macolin Convention), and the
Finnish Centre for Integrity in Sports (FINCIS).

In the same vein, Slovenia has established an NGO/GO and intersectoral working group to
prepare the foundations of a fully independent agency for sport integrity.

Within the sports movement, besides the activities of the IOC, the Athletics Integrity Unit (AIU) is
a good example of a multi-task organisation. The AIU is an independent body that was created by
the International Association of Athletics Federations (IAAF), following the corruption scandal
involving its former president. The AIU managescreated by World Athletics to oversee all integrity
issues - both doping and non-doping - for the sport of athletics. The remit of the AIU includes
anti-doping (in respect of which it has a reputation as being a world-leading Anti-Doping
Organisation), the pursuit of individuals engaged in age or competition results manipulation,

33
investigating fraudulent behaviour with regards to transfers of allegiance, and detecting other
misconduct including bribery and breaches of betting rules.

Conclusions

No matter which policy area they cover, successful sports integrity policies are those which
manage to effectively mobilise multi-stakeholder support.

In the early 2010s, some betting operators presented a study during the EU Council’s Sports
Working Party which they believed proved that doping is a more serious problem than match-
fixing because there “were many more reported doping cases”. Although its conclusions were
erroneous, this study mostly reflected a successful system of multi-stakeholder co-operation in
anti-doping. The results of that co-operation are the number of the cases turned up, unlike in
match-fixing which lacks similar co-ordination, tools and structure.

That’s not to say that match-fixing cases are not being detected – they are. And theThe entry into
force of the Council of Europe Convention on the Manipulation of Sports Competitions - the only
international rule of law instrument in this area - will accelerate and enhance co-operation, in
particular within the network of states party to the Convention. But a multi-stakeholder approach
here may quickly reap the same kind of dividends that it has in anti-doping.

34
 H) Whistle-blowers and free media

The role of journalism in detecting breaches of integrity in sport

When British investigative journalist, Andrew Jennings, began investigating the International
Olympic Committee (IOC) in the early 1990's, some of his colleagues made fun of him for looking
at what they thought to be an unimportant area of public life. Writing for the International
Review for the Sociology of Sport, he recalls his own replyhe wrote: "Sports organisations are in
the public sphere. They're backed by public money. They wield power. Why should they escape
scrutiny?".

Despite the diligent work of Jennings to uncover corruption in sport organisations, the fact is that
the vast majority of media coverage of sports does not contain much scrutiny. The International
Sports Press Survey (Horky and Nieland 2011) showed that newspaper coverage in 22 countries
focused almost exclusively on sports performances in the form of match reports, comments on
performances and previews of upcoming competitions and matches.

JWhat’s more, journalists rely on athletes, coaches and representatives from sports organisations
to produce their stories, and access to these sources is often carefully managed by sports
organisations. This reliance has contributed to the increasing commercialisation of sports news,
where journalists agree to mention sponsors or advertisers to get interviews. The process has
also promoted self-censorship as journalists fear being cut off from key sources if they are too
critical. In turn, the danger has arisen that parts of the sector rarely enjoy sunlight – the best
disinfectant when it comes to maintaining integrity.

The watchdogs of sport - Investigative journalists and whistle-blowers

The task of uncovering issues which some stakeholders in sport would prefer to be kept in the
dark mainly falls to an increasingly smaller group of investigative journalists - many of whom are
independent freelance professionals who go without the support and protection of a larger
media organisation. They may painstakingly put together their own stories, but some also work
on unravelling the stories hidden in documents and information leaked by whistle-blowers.

A whistle-blower can be defined as “any person who reports or discloses information on a threat
or harm to the public interest in the context of their work-based relationship, whether it be in the
public or private sector”.30

In the sports sector, such information may concern issues related to doping, manipulation of
sports competitions, bribery, corruption, conflicts of interests, discrimination, racism or abuse
(including physical and sexual abuse). Because such wrongdoings can be accompanied and
sustained by strong forms of organisational silence (or ‘omerta’), whistle-blowers can play an
invaluable role in their detection, investigation and eventual sanction. Experience in corporate or

30
Council of Europe Recommendation CM/Rec(2014)7 on the protection of whistleblowers, adopted on 30 April 2014

35
public administration settings shows that whistle-blowers can effectively participate in self-
regulation and risk management within organisations.

Despite their prominent role in the safeguarding of sport integrity, recent examples of whistle-
blowers in sport demonstrate the difficulties that internal actors face when they want to break a
silence and signal serious wrongdoings. For example, it took several years for some American
gymnasts to be listened to when they accused a well-established national team doctor of
repeated sexual abuse. Likewise, the cases of doping in Russia may not have been revealed
without the decision by several Russian sports actors to ‘go public’ and denounce doping systems
- among them, the runner Yulia Stepanova who left her homeland and needed to ask for
protection.

Yet freeFree speech and investigative journalism are instrumental in fighting against any
breaches of integrity. They have sometimes shown to be more effective than internal control
processes and law enforcement, by uncovering cases which trigger dramatic reforms.

Case studies

In 2008, Canadian investigative journalist Declan Hill published The Fix: Soccer and Organised
Crime, a book that details the methods and motives of match-fixers in football.

According to Hill, the book has helped spark over thirty national police investigations, and the
author has also testified about his findings before the International Olympic Committee, the
Council of Europe and numerous national sports agencies.

In 2014, a senior figure inside FIFA leaked millions of documents to The Sunday Times. These
so-called ‘FIFA Files’ led to a series of articles that alleged that Mohamed Bin Hammam, Qatar's
top football official, had masterminded a plot to buy the 2022 World Cup for Qatar.

In 2014, German investigative journalist Hajo Seppelt's documentary, Doping Top Secret: How
Russia makes its winners, was broadcast on ARD and presented evidence of state-sponsored
systematic doping in athletics and other sports in Russia. The documentary caused several
figures in international sports organisations and anti-doping institutions to either resign from
their posts or to be suspended. In June 2016, a follow-up documentary led the International
Association of Athletics Federation to extend its suspension of the All-Russia Athletics
Federation, and almost no Russian athletes were allowed to take part in the 2016 Olympic
Games.

In 2016, more than 60 journalists working for media in 12 different countries partnered within
the framework of the European Investigative Collaborations network and began publishing
stories based on the largest leak of documents in the history of sport. Football Leaks have
revealed corruption among top officials, clubs, agents and players in many different countries,
and the stories continue to be unearthed and published.

36
 In 2016, the local US newspaper Indianapolis Star's investigative team uncovered sexual abuse
within USA Gymnastics, believed to have affected more than 150 young girls including Olympic
champion Simone Biles. Team doctor Larry Nasser was later sentenced to 175 years in prison
for sexual assault, the Board of USA Gymnastics was reorganised, and the US Olympic
Committee announced changes to its policy for reporting abuse.

The dangers of sports journalism

Reporting on sport comes at a price for some journalists. In 2017, an academic study published in
the book The Assault on Journalism (Carlsson and Pöyhtäri 2017) showed that sports journalists
are regularly subjected to violations of media freedom and personal safety.

Analysing 78 reports in the public domain about incidents that took place between 2010 and
2016, the study documented that sports journalists have been banned from press conferences,
stadiums or events, and some have even had their passports seized or been denied accreditation
when trying to enter a country to cover a sports event. The personal safety of sports journalists
was compromised through arrests and detentions; physical and verbal assaults; abduction;
attacks; physical, verbal and digital threats of violence or death; legal actions; damage to
property; personal and digital sexual abuse; and killings.

In some countries, journalists have received so many death threats for working on sensitive
issues, that they have had to hire security personnel to protect them and their colleagues. In one
case, a Spanish judge issued an injunction, ordering 12 European media organisations to stop
publishing revelations from Football Leaks.

Media organisations and journalists are integral parts of a sports world fuelled by strong
economic interests and high emotions, where a wide range of stakeholders are monitoring and
trying to affect how journalists cover issues which are material to them. The high number of
stakeholders is a key feature of this specific sub-field of the safety of journalists. Perpetrators of
violations against sports journalists come from a range of groups including sports fans, athletes
and coaches, owners and officials of sports clubs and associations, and international sports
federations. Police and political authorities also feature prominently on the list, particularly in
relation to mega-events. Even the Islamic terrorist group Al-Shabaab in Somalia has been
targeting and killing sports journalists for glorifying what the group calls “satanic sports”.

Considering the wide range of stakeholders in sport as well as the current low level of research
and understanding of the threats faced by investigative journalists in sport, it is difficult to
identify specific challenges that should be overcome to ensure they can continue to act as
watchdogs. Just like for other risks to sport integrity, we need to determine the exact nature of
the problems, their extent, their impact, how they should be handled, and who should be
involved in protecting sports journalists from harm or (self-) censorship.

It is an important first step to acknowledge that the problems exist. The next step should be to
build mechanisms that ensure that sports journalists are encouraged to report the violations they

37
experience so that an informed search for solutions can begin. And while developing integrity
policies, public authorities should pay attention to ensure that the protection of journalists is
addressed.

Protection of whistle-blowers in sport

In order to promote and protect whistle-blowers, several models of procedures and policies can
be developed by sports organisations.

First of all, confidential and reliable reporting lines need to be accessible by everyone. They can
take the form of hotlines, a secured web platform, mobile or computer application, a mailbox, or,
ideally, a combination of these. A trustworthy recipient needs to be empowered with collecting
and handling the whistle-blowing reports, with sufficient capacities and autonomy of action.
Organisations can also protect whistle-blowers by offering them free advice and support (and if
necessary, physical protection), rewarding them, and by explicitly prohibiting and sanctioning
forms of retaliation against them. Then, the whistle-blowing policy needs to be widely
communicated and promoted at every level of the organisation.

Sports managers have the responsibility to set a positive tone and ensure that the inner
organisational culture promotes the values of integrity, ethics and dissent. One of the most
advanced models for whistle-blowing protection in sport may be the World Anti-Doping Agency
(WADA) Speak Up system. It includes a secured reporting app, detailed online information on
relevant procedures, and the possibility to enter into a ‘Whistle-blower Agreement’ with rights
and responsibilities outlined for both signatories. Another note-worthy example of whistle-
blowing protection is the IOC-UNODC Reporting Mechanisms in Sport: A Practical Guide for
Development and Implementation.

Sports authorities seeking to implement whistle-blowing policies have several difficulties to

overcome. One of the most important is to inspire trust. Sports actors may take personal risks by
speaking up, and they need to feel that they will be supported, and that the private information
they provide will be confidentially and fairly handled. The hierarchical and geographical distance
between international or national sports organisations and local sports actors may discourage
potential whistle-blowers. Another issue is cultural: in sports organisations in particular, the value
of loyalty, group identification and the focus on sporting performance may inhibit dissent and
whistle-blowing. A value shift is necessary to empower these actors. Communication, education
and awareness-raising programmes need to underline that engaging in the protection of sport
integrity does not automatically contradict group loyalty and personal performance.

In the case of athletes, possible serious risks related to the future of their sport careers are an
additional complication when it comes to whistleblowing. This factor is especially important if an
athlete wishes to whistle-blow on an organisation, body or a person which is in a dominant or
decisive position vis-à-vis the athlete. As a result, athletes should be able to use different tools
and mechanisms, including those from outside sport organisations, to make them feel most
comfortable. Additionally, in situations where athletes have a positive obligation to report

38
according to their sport rules (such as reporting any approaches in match-fixing), it is important
to make special efforts to recognise the validity of reports made outside of sport organisations
mechanisms.

I) Protection of Human Rights

The question of sport and human rights has recently become a key item on the agenda when it
comes to discussions on international sports policy. This reflects the universal nature of human
rights, as well as the major role that sport plays in the lives of a large part of the world’s
population. But this area has various dimensions to it.

The first issue is the protection of human rights in sport, something which is not only related to
the protection of athletes and other participants in sport activities. Restrictions to freedom of
expression or freedom of association must also be handled with care. Sport integrity policies
often involve disciplinary proceedings, investigations and sanctions, which should be enforced
with due regard for human rights. Principles such as the right to a fair trial or the right to the
respect of private and family life are both sensitive issues when it comes to the above-mentioned
policies.

In particular, the requirements stemming from the right to a fair trial within the sports justice
system is controversial, especially with regard to the independence of the body giving the
judgment and to the proportionality of the punishment.

Similarly, measures in the fight against doping and manipulation of competitions must not
unlawfully interfere with people’s right to privacy. There is an emerging case-law related to sport
from human rights courts such as the European Court of Human Rights. It is important that the
sports movement and government bodies responsible for sport ensure that the necessary
procedures for the protection of sports ethics, fair competition and athletes are carried out with
due regard for fundamental rights, as they emerge from this case-law.

Another aspect to consider is the mainstreaming of a human rights perspective into sports
policies – for example, the overall impact of sports events on the rights of concerned populations
or workers in the supply chain.

This has been in particular focus in recent years due to the selection of countries with
controversial human rights records as hosts for major sports events including the Olympic Games
and the FIFA World Cup. Several organisations, including FIFA, the IOC and UEFA, have included a
human rights dimension into their selection criteria for major sport events, especially focusing on
the social impact of the event.

The question has been debated in a multitude of contexts over the past years, i.e. through direct
dialogue between sports organisations and human rights organisations/civil society coalitions
(such as Amnesty International, Human Rights Watch, the Sport and Rights Alliance) and through
partnerships with UN organisations (the International Labour Organization, for instance).

39
Since 2018, the creation of another relevant actor in this field, the International Centre for Sport
and Human Rights has given more energy and cohesion to this movement. The Centre brings
together key stakeholders to share knowledge and improve stakeholders’ ability to include
human rights considerations in their governance and operations.

Last but not least, the introduction of a human rights perspective in sport also includes the fight
against any form of discrimination and the promotion of diversity in and through sport. In this
sense, the promotion of ‘sport for all’ entails the idea of a fundamental right to practise sport,
which is mentioned in several international recommendations, as well as in some national
constitutions.

The right to recreational activities, including sports, can also be found in other international
agreements, such as the Convention on the Elimination of All Forms of Discrimination against
Women (1979) and the International Convention on the Rights of the Child (1990). The UN
Convention on the Rights of Persons with Disabilities (2007) Article 30 recognises the rights of
persons with disabilities to participate in sporting activities at all levels and on an equal basis with
others. More recently, UNESCO enacted a right to practise sport in the Revised International
Charter of Physical Education, Physical Activity and Sport of 2015.

Despite this growing trend, the right to access sport is still not considered as a right by
international treaties. Nevertheless, the Sustainable Development Goals (SDG) have raised a lot
of attention in many countries, and governments are eager to work on them. Sport can play an
important role in achieving many of the SDGs, whilst sport participation features prominently in
discussions surrounding sustainable development (e.g. the 2030 Agenda for Sustainable
Development A/RES/70/1, paragraph 37). The Council of Europe is in favour of advocating a
rights-based approach to sports practice and of promoting an enforceable fundamental right to
sport.

D) Education, prevention and awareness-raising

Introduction

Education and awareness-raising are crucial aspects of any action when stakeholders are keen to
achieve sustained success. Sport is no exception. It is impossible to think of complete integrity,
sport protection or any other plan without considering the educational element that sits beneath
them.

An awareness-raising campaign is crucial at the beginning of any project aimed at changing the
culture of a country or of specific groups and education and prevention are applicable to all five
policy areas promoted in this project.

Education has two main roles in respect of integrity in sport:

40
 • To support the fight against the risks posed
• To build prevention strategies – including by instilling values associated with sport in
children and youth – in order to avoid those risks.

Prevention

It is helpful to define the word prevention in respect of sport integrity. One of the definitions we
can use is the following: the act of prevention – generally, it is to stop something (usually
unpleasant)undesirable from happening and/or to minimise its consequences.

One dimension of prevention in this case is to reduce the opportunities for wrongdoing. This
encompasses promoting good governance of sport organisations and increasing respect for the
rights and welfare of all involved in sport, including athletes. As we’ve described,
deficienciesDeficiencies in these areas can lead to an increased vulnerability to threats to
integrity.

Another dimension of prevention is to stop behaviour that can cause damage to athletes, sport
credibility, values, and fairness. Awareness-raising, education, and training in this field can play a
significant role. But what are the best tools and how we can use them?

1. Awareness-raising
This is the state or condition of being aware; having knowledge or consciousness. The object of
an information drive is to raise awareness about a particular phenomenon to achieve this state.

2. Education
Education can be a means to empower children and adults alike to become active participants in
the transformation of their societies. Learning should focus on the values, attitudes and
behaviours that enable individuals to learn to live together in a world increasingly characterised
by diversity and pluralism. It also plays a crucial role in helping people to become active
participants in the life of their society. As an example, education can strengthen skills and
attitudes such as the courage to report (see the section on whistle-blowing), as well as the
listening skills necessary to establish a ‘speak-up’ culture.

3. Training
Training consists not only of giving information about something, but also aims to build capacity,
and create new models of work for those being trained.

Using educational tools

The first step of a prevention strategy delivered through education is raising public awareness
within a community. In order to raise public awareness about the importance of protecting sport,
a specific campaign about relevant issues should be created.

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First steps

Know and establish the target audience

A primary component is to know who your audience is, to bring them together, empower and
connect them.

Set objectives for the awareness campaign

For the campaign to be a success, it is important to establish objectives that can make it social
and interesting.

Educational events
People are interested in attending events where they can learn and connect with people who
have the same interests.

Create and distribute informative pamphlets or brochures

Pamphlets or brochures can summarise informative points about your cause and give
participants something to bring home with them, to reinforce the main points discussed during
the event.

The role of media and social media channels for awareness raising
Media can play a significant role in giving your efforts the profile they need. Having a good
relationship with journalists and inviting them to events can make a difference in raising
awareness on a larger scale.

Social media platforms are becoming more and more important, notably to reach to youth and
the general public. They are the most accessible mode of information exchange because posts
can be shared. If you create social media accounts for your cause, you can keep in contact with
yourSocial media allows organisations to maintain ready contact with their participants or engage
with newcomers and related communities.

During or after your awareness-raising campaign, you should start to work on narrowing your
awareness-raising to a more targeted group - sport actors and other stakeholders.

Regional or national sports bodies are a crucial channel for reaching athletes and their entourage
with educational programmes. They might consider these programmes an obligation for sports
associations and clubs or encourage them to set up their own educational programmes. Regional
and national bodies can do a lot in this field: they are better-placed to assess the needs of their
people and create additional training, seminars or conferences.

In the field of anti-doping, the Ssixth Conference of Parties to UNESCO’s International Convention
against Doping in Sport adopted Resolution 6CP/3 through which governments “recognize that
values-based education programmes strengthen the prevention of doping and support deterrent
measures, as well as the transfer of values to all spheres of life” and were called upon to ensure
that funding is allocated to the “planning, implementation, evaluation and monitoring of anti-

42
doping education programmes”, comprising anti-doping education, information and values-based
education.
theThe key role of education is also highlighted encapsulated in WADA’s the World Anti-Doping
Code International Standard for Education.

Finally, it’s important to organise education opportunities which bring different stakeholders
together to meet and discuss the issues, with the aim of developing co-operation among them.

E) Monitoring implementation and compliance – and providing remedies

In the last two decades, sport has become an even more important point of public interest and,
with commercial stakes increased, it is both more vulnerable to integrity problems and subject to
more public scrutiny. Moreover, sport is now employed as a source of soft power, both
internationally and domestically. As a result, sport integrity is becoming more of a focus for both
sports organisations and public policy-makers.

As we have previously discussed, sport integrity as defined here covers a whole range of areas -
from doping, through personal behaviour to good governance.

In these areas of integrity, many of the legal provisions, private regulations and policies are
supported by compliance systems, which are governed either by public authorities
(governmental authority, intergovernmental organisation) or by private entities (sports
organisations, WADA, etc).

These compliance systems are needed to steer and improve any policies, but they are particularly
meaningful in the area of sport integrity, since the issues at stake include people’s safety, as well
as their fundamental rights.

In addition, the systems are also expected to ensure an equal playing field in sports competitions,
taking into account the high level of investment in sport made by athletes, by governments, and
by related industries (e.g. sponsors, broadcasters, betting operators, etc). In the next sections,
we examine what compliance means in sport integrity.

Case Study
Namibia is working on a National Sport Development Index that will track sport data on a regular
basis to support monitoring and compliance with key integrity standards.

Monitoring and evaluation of public policies

Most standards or policies aim to respond to a public problem or risk. Once a problem is
identified, the means are deployed to prevent or mitigate it. When designing policy to address a
specific problem, the following path should be taken:

43
 • Inputs - Define the resources that can be mobilised and allocated, including a normative
framework
• Outputs – Define what is produced with the input, e.g. training, advice, platform for
dialogue, report
• Immediate outcomes – Understand the immediate expected effect of the outputs, e.g.
the gain in knowledge or awareness, the identification of measures to be taken, a change
of behaviour
• Mid/long-term outcomes – Gauge the consequence of the immediate outcomes on the
final beneficiaries (citizens, athletes), e.g. service providers enjoy their rights, a level
playing field is guaranteed for all athletes
• Monitoring - Track the progress towards achieving an objective, and in particular the
inputs and outputs, while beginning evaluation by looking at the outcomes and assessing
if the situation has changed as expected, i.e. has the intervention made a difference?

Compliance systems - Why and on which standards?

A compliance framework can be thought of in two different ways. On the one hand, it can be a
set of regulations while on the other, it can mean the establishment and implementation of
means to ensure that those regulations are enforced.

In either respect, monitoring and evaluation can be used to steer regulations or policies, to
review them, to identify necessary improvements, to assess compliance with a standard, to
certify it, to offer redress and even to sanction misbehaviour.

Monitoring and remedy methods

Many tools and methods can be used for the purpose of monitoring and evaluation. These
include:

• Peer-review
• Hearings
• Desk reviews
• On-site visits
• Audits
• Collective complaints
• Surveys
• Collective or individual remedies.

Remedies are managed on the governmental side by judicial authorities, mediators and
independent authorities. On the sport side, sports organisations have disciplinary and arbitration
bodies at international level, while the jurisdiction of the Court of Arbitration for Sport (CAS)
constitutes the ultimate remedy.

44
Based in Switzerland, CAS can be held accountable to the Swiss Federal Tribunal if its procedures
are not compliant with fundamental rights. And Switzerland is then accountable to the European
Court of Human Rights.

Those judicial or quasi-judicial remedies are essential parts of the structure of sport integrity, but
are costly to mobilise and, even though case-law does impact general policies, are more suited to
testing individual cases than inducing systemic changes. As a result, they should also be
complemented by monitoring and evaluation.

In anti-doping - one of the most established areas of sport integrity involving sports
organisations, governments and specialised organisations - compliance is ensured by multi-layer
systems. At an individual level, disciplinary and judicial proceedings sanction infringements, but
and the compliance of Ssignatories with to the World Anti-Doping Code is monitored by a global
body - WADA. WADA-accredited laboratories are subject to certification processes guaranteeing
their compliance with the relevant standards.

The compliance of public authorities with their commitments made under international anti-
doping Conventions is the exclusive preserve of the

Alongside that structure, WADA-accredited laboratories are subject to certification processes

guaranteeing their compliance with the relevant standards. On the side of public authorities, the
States Parties to UNESCO’s and the Council of Europe’s relevant conventions are also subject to
monitoring mechanisms set up by these international organisationsestablished pursuant to those
Conventions. These institutions identify how Governments can be enabled and empowered to
implement their commitments as effectively as possible. And on top of all these compliance
systems, overall anti-doping policy, as defined by the World Anti-Doping Programme, is evaluated
and updated on a regular basis by a World Anti-Doping Conference. This is why theTo support
this the Eeighth Ssession of the Conference of Parties to UNESCO’s International Convention
against Doping in Sport adopted, in 2021, the Operational Gguidelines and Framework for
strengthening the implementation of the Convention31.

Anti-doping’s multi-layered model can provide a model for other sport integrity challenges,
involving as it does, sports organisations, specialised organisations and public authorities.

Publicity and co-operation

As far as is possible, the information collected within the framework of compliance systems
should be made public. PThat’s because the publication of monitoring results is a powerful
incentive for organisations and governments to comply with standards. As an example, in the
case of UNESCO’s Anti-Doping Convention, the list of non-compliant States Parties, as decided by

31
https://unesdoc.unesco.org/ark:/48223/pf0000381120

45
the Conference of Parties, is published online and communicated to key international
stakeholders involving both intergovernmental organizations and the sport movement.

Making this information available is also a key part of increasing mutual confidence between the
partners involved in a sport integrity policy area, as well as to gaining trust from the public on the
actions of those involved.

Likewise, compliance systems should not be set up by the organisations and public authorities in
charge of the relevant policies in a vacuum. Best practice dictates that they should involve
external expertise, independent bodies and seek information from the media and NGOs,
including those representing the ‘target groups’ and ‘final beneficiaries’ of the policies (see the
section on investigative journalists and whistle-blowers).

A multi-stakeholder, iterative approach leading to the development of a framework to monitor

the chain from investment, through policy formulation and implementation right the way
through to compliance is key to quantifying the impact of our integrity strategies.

Overview of compliance systems used at international level in the field of sports integrity

International organisations Sport governing bodies

Standard/Regulation Compliance system - Standard/Regulation - Compliance
Examples Examples system -
Example
Human rights UN Convention on Provisions in federations’
the Rights of Persons statutes and human rights
with Disabilities policies
Athletes ILO Conventions Representations of Professional contract, Ethics
non-observance of competition and committees,
conventions participation conditions disciplinary
Workers Complaints of non- Agreement with host committees,
observance countries CAS
Spectators CoE Convention on Questionnaire Regulations on safety, Agreements
Spectator Violence Evaluation visits security and services with
and Misbehaviour organising
at Sports Events and committees
in particular at Site visits
Football Matches
CoE Convention on
an Integrated Safety,
Security and
Service Approach at
Football Matches and
other Sports Events
Children UN Convention on Hearings, reports International Safeguards for IOC
the Rights of the Children in Sport Safeguarding
Child officer
FIFA Guardians Child
Safeguarding Programme

46
 FIFA’s dedicated Child
Protection and Safeguarding
Manager
CoE Convention on Hearings, reports, ad
the Protection of hoc onsite visits
Children
against Sexual
Exploitation and
Sexual Abuse
Integrity
Doping UNESCO and CoE Reports based on World Anti-Doping Compliance
conventions against questionnaires and Programme with the
doping in sports evaluation visits Code
Operational guidelines Accreditation
and Framework of of
Consequences laboratories
Legal Framework CAS
Competitions CoE Convention on Competition, participation
manipulation the Manipulation of regulations
Sports Competitions
Governance UNODC United Olympic and Sports Self-
Nations Convention Movement evaluation
against Transnational Codes of Conduct (i.e. BUP) tools (i.e.
Organised Crime ASOIF
UNODC Convention indicators)
against Corruption

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 F) Gender and youth mainstreaming in sport integrity policies

Sport is still the most popular social activity for young people. And although sport integrity
policymakers primarily see young people as volunteers, beneficiaries or target groups, there is still
room for them to contribute as policy-makers.

Research examining young people’s development in and through sport has mostly focused on
young people as a general group. Comparatively less attention has been devoted to the
examination of gender pathways.

Throughout history, girls and women have had to fight for equal rights and their access to sports
participation. In the past few decades, great progress has been made to increase the influx of girls
and women into physical activity and sport, as well in the legislation and decision-making around
that process.

Mainstreaming is a recognised methodology ensuring that the concerns and experiences of specific
social cohorts (e.g. youth/women) are an integral part of the design, implementation, monitoring
and evaluation of policies and programmes. Integrating gender-mainstreaming ensures that all
genders are treated equally, so that unfair treatment does not become entrenched.

Gender and youth and sport

While we are getting closer and closer to reducing inequalities every day,G girls and women still
have fewer opportunities, less investment, training and corporate attention than men when they
play sports. Efforts towards eliminating gender discrimination in sport, first began in 1994 with
the International Working Group on Women and Sport (IWG) and the first World Conference on
Women and Sport, which adopted the Brighton Declaration.

Unfortunately, despite a broad mobilisation, sportSport is regrettably not a sector in which gender
equality progresses quickly. Despite apparent consensus on the importance of gender equality in
sports participation and sports coaching leadership, women still do not enjoy de facto equal access
to sport. However, a growing number of sports policies and strategies are addressing the gender
dimension with specific measures.

The specific needs of both young people and women tend to be overlooked during the policy-
making process and mainstreaming processes can help ensure that policy-making is fit for serving
these groups.

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 According to a recent survey carried out within the ALL IN project, in Europe,
women make up only:

• 31% of the members of a sports club or federation

• 8% of the presidents of the national Olympic sports federations
• 23% of the board members of the national Olympic committees
• 1 in 5 employed elite coaches in national Olympic sport federations
• 7% of the presidents, 18% of the vice-presidents and 22% of all
board members in the sport federations and
• 22% of the employed elite level coaches in the sport federations.

When it comes to young people, the story is similar.

Millions of children and young people take part in sporting activities every day across the world,
many of them purely for recreation and fun. Others may participate in sport for development
programmes, while for some sport may be their chosen career path - as talented athletes, coaches
or officials. Sport is also used as a vehicle for diverting young people from anti-social or criminal
behaviour.

Given their wide participation in the movement, meaningful youth engagement and leadership
within sport is vital for fostering creative and innovative solutions and may even be significantly
important in the future transformation of sport. Ensuring the organisation of Games and achieving
the sector’s goals only seem possible with the active participation of today’s generation of 1.8
billion young people.

Therefore theThe views of young people today need to be considered with equal weight, across
implementation and decision-making, to strategy and conceptualisation. The immense growth of
young entrepreneurs, coupled with the fact that more resources are being dedicated to education
than at any other point in our history, highlights how present and relevant youth is in shaping the
present-day.

Youth participation in the decision-making processes should be inclusive and balanced. Proactive
investment, policies and strategies can help address inequalities in sport participation and
leadership (SDG 5.1, 5.5 and 5.c).

49
 Definition of youth

The definitions that use 15- 24 (The United Nations) and 15-19, 20- 24 and 25-29 age cohorts to
define ‘youth’ (Dashboard on EU youth indicators), fairly serve their statistical purposes for assessing
the needs of the young people and providing guidelines for youth development.

Apart from the statistical definitions, the meaning of the term ‘youth’ varies in different societies
around the world, especially with the changes in demographic, financial, economic and socio-cultural
settings.

Being identified directly in sport policies means that girls, women and young people in general are
seen as part of the solution and as having a legitimate interest in contributing to shaping the
agenda.

A report by the European Commission published in 2014 found that men in EU states exercise or
play sport more than women. This disparity is particularly marked in the 15-24 age group, with
considerably more young men tending to exercise or play sport on a regular basis than young
women. Just 15% of men aged 15-24 never exercise or play sport, compared with 33% of women
in the same age group.

Both participation and governance in sport have traditionally been dominated by men. The amount
of regular activity that people do also tends to decrease with age. A majority of 15-24-year-olds
(62%) exercise or play sport regularly or with some regularity but this falls to 46% in the 25-39 age
group, 39% for 40-54-year-olds and 30% for the 55+ age group.

This research stresses the importance of taking action among young women (15 or older) because
this is when the level of inequality is at its largest, and because their level of activity will then
decrease with age if the habit of playing sport or undertaking physical activity is not acquired by
this point.

In many cases, sport policies and, in particular, sport integrity policies do not reflect women’s and
young people’s perspectives and do not address the roles that women and young people could
play. Rather, they view them as playing a more passive role - for instance emphasising their status
as victims at the centre of societal problems or as mere beneficiaries of policy implementations -
rather than key shapers of them, as they ought.

Mainstreaming as a strategic tool

Mainstreaming is a globally accepted strategy for promoting gender equality. It is an approach to

policy-making which ensures that gender/youth perspectives and attention to the goal of equality
are central at every stage: policy development, research, advocacy, legislation, resource allocation,
implementation and monitoring.

50
The concept of gender mainstreaming was first introduced at the 1985 Nairobi World Conference
on Women. It was established as a strategy in international gender equality policy through the
Beijing Platform for Action, adopted at the 1995 Fourth United Nations World Conference on
Women in Beijing, and subsequently adopted as a tool to promote gender equality at all levels.

Mainstreaming is based on the recognition that women and men, and youth and older generations
have different needs but also have different living conditions, including unequal access to and
control over power, money, human rights, justice, resources and decision-making. Mainstreaming
therefore means looking at the human implication of any activity, highlighting the inequalities and
differences between women and men, younger and older, and thus underlining the potential
differential impact of policies on everyone. This leads to designing policies that benefit younger
and older girls and boys, and women and men equally.

Mainstreaming leads to a paradigm shift in approaching public policy-making. ‘Reflecting’ –

‘addressing’ – ‘being sensitive’ – ‘being responsive to’ gender/youth issues refers to involving/
engaging younger and older women and men and ensuring their participation in decision-making
processes on the one hand, and assessing the impact of a policy/project/programme targeting
younger and older women and men on the other.

Why?

PIn many cases, public policies are assumed to be neutral towards genders and generations but
are in factin reality are frequently based on the needs of the dominant group in society or on the
needs of those who have traditionally been the decision-makers. Both groups are mostly men. As
a result, public policies have often not taken women’s and young people’s differing needs and
situations into account.

Several studies have shown that inequalities have direct costs. Evidently, decisions regarding
public policies and services which do not fully consider the needs and situations of all final users
may lead to inappropriate solutions, as well as an imperfect allocation of public funds.

Mainstreaming is a strategy designed to improve the quality of public policies, programmes and
projects, ensuring a more efficient allocation of resources. Better results mean increased
wellbeing for all, and the creation of a more socially just and sustainable society.

What is required?

Equality issues need to be mainstreamed at all stages of policy-making, but it is especially

important to take them into account at the policy design stage, when the problems, concerns
and needs of the beneficiaries are identified and the ways to address them are defined.

51
 Public policy designs are formal processes aimed at ensuring the best balance between the scope
and means of intervention by the stakeholders, and the public issue that is addressed – all based
on sets of evidence that legitimate the policy.

How?

Consideration for women and young people can be integrated in all phases of the policy cycle:

• Situation analysis - Young women and men’s condition and position needs to be
researched. Young people can act as peer researchers and information providers in the
process.
• Planning and implementation (policies/programmes) - Young women and men should be
a target population, and young people’s views and aspirations should be taken into
account.
• Monitoring and evaluation - There should be youth/gender-specific indicators, including
those related to the quantity and quality of youth participation in the project. Monitoring
and evaluation should also involve asking young people’s views of how much progress has
been made and what the challenges are.
• Resources (budgeting) - Specific line items should cover youth/gender-specific activities
and any mechanisms required to be put in place to secure their participation in all stages
of the project.

Conclusion

Sport integrity policies are not gender neutral; women and men and young and older people are
not involved in the same way in sport integrity matters. Behaviour towards violence, abuse, drugs
and addiction, and corruption have a gender-dimension which should be taken into account
when these issues are addressed in the context of sport. Ultimately, mainstreaming in sport
integrity policies will contribute to making sport ethical, safe and inclusive for women, men, girls
and boys.

Useful tools and references

Table 1: The list of core policy documents

European Commission Council of Europe The United Nations The Commonwea
Secretariat
The White Paper A new Declaration The future of the The Beijing Platform for Action Youth Mainstream
impetus for European youth Council of Europe youth policy: Area L – ‘The Girl Child’ Development Plan
(2001) Agenda 2020 Transforming You
London, p.7.

52
Table 1: The list of core policy documents

The European Youth Pact Recommendation CM/Rec The General Assembly of the
(2005) (2017)4 of the Committee of United Nations Resolution
Ministers to member states on 68/130 Policies and
youth work programmes involving youth
(2013)
The EU Youth Strategy (2010- The UN Youth Strategy (2018):
2018) YOUTH 2030 Working with and
for young people
The UNESCO Operational
Strategy on Youth (2014-2021)

European Parliament UNICEF: Adolescent and Youth

Resolution - The EU Strategy Engagement Strategic
for Equality between Women Framework
and Men Post-2015 (2015) UNESCO: Operational Strategy
on youth (2014-2021)
WHO: The global strategy for
women’s, children’s and
adolescents’ health (2016-
2030), Survive, Thrive and
Transform
UNDP’s first Youth Global
Programme for Sustainable
Development and Peace –
Youth-GPS (2016-2020)

Section bibliography

• Commonwealth Secretariat (2017), Youth Mainstreaming in Development Planning:

Transforming Young Lives, London, p.7, available at
https://thecommonwealth.org/sites/default/files/events/documents/YMDP_9781849291
644.pdf
• European Institute for Gender Equality provides practical examples of gender
mainstreaming in policy areas of youth (Austria, Ireland) and sport (UK, Finland).
• Commonwealth Secretariat 2008, Commonwealth Youth Ministers Meeting Colombo, Sri
Lanka, 27-30 April 2008, Youth mainstreaming as a strategic tool for youth development,
Commonwealth Youth Programme - 2008_Youth_Mainstreaming_Development_Eng.pdf

53
• Commonwealth Secretariat 2015, Sport for Development and Peace and the 2030 Agenda
for Sustainable Development -
http://thecommonwealth.org/sites/default/files/inline/CW_SDP_2030%2BAgenda.pdf.
• European Commission (2011), Dashboard on EU youth indicators, Commission staff
working document On EU indicators in the field of youth, Brussels - indicator-
dashboard_en.pdf.
• European Commission (2018), The situation of young people in the European Union,
Commission Staff Working Document, SWD(2018) 169 final, Brussels -
NC0118604ENN.en.pdf
• Joint meeting of the Executive Boards of UNDP/UNFPA/UNOPS, UNICEF, UN-Women and
WFP
19 June 2017 New York, Working with adolescents and youth to achieve the Sustainable
Development Goals, - JMB-2017-Topic_2-Youth-EN-2017.05.23.pdf.
• Website of the Focal Point on Youth, UNDESA - http://undesadspd.org/Youth.aspx
• Website of the European Institute for Gender Equality - https://eige.europa.eu/
• UNITED NATIONS: YOUTH - https://www.un.org/development/desa/youth/
• UNESCO - https://www.youthandsport.org/priority-areas
• UNICEF and young people - https://www.unicef.org/young-people

54
Part 4: Compendium of factsheets on the five policy areas

Introduction

With improved sport integrity as the aim of Action 3 of Kazan Action Plan, five areas have been
identified to provide some guidelines to public authorities for the development of policies in
these domains.

The five policy areas are:

1. Preserving the rights, safety and security of athletes, spectators, workers and other
groups involved32

This policy area aims to preserve the rights, physical integrity, health and safety of all those
involved in sports and, in particular, in sports events. Aspects such as occupational health and the
safety and security of athletes and spectators should be included in this policy. Moreover, the
economic, social and environmental impact of major sports events should also be addressed,
especially with regard to workers, local populations and businesses, but also to volunteers. The
aim is to ensure the groups’ rights are protected and that they can benefit from the positive
externalities of major sports events. Since this policy area is often developed in distinct public
policies, the descriptive elements in the factsheet have been divided by target group, mainly for
the purposes of clarity in the document: These groups are

• Athletes
• Spectators
• Workers and other groups involved.

2. Preventing and addressing harassment and abuse in sport

This policy area deals with harassment and abuse in sport in order to ensure the right to a safe
and enjoyable sport environment for all. Harassment and abuse cover several aspects, namely
psychological, physical and sexual harassment and abuse, as well as neglect. With reference to
the conceptualisation offered by the Centre for Sport and Human Rights, special attention should
be paid to the risks faced by those who are more often victims of harassment or abuse, in
particular children, women and girls, human rights defenders, LGBTI+, migrants, minority and
ethnic groups, indigenous people, historically disadvantaged communities, and the physically and
mentally less abled.

3. Fostering good governance of sport organisations

32
The International Centre for Sport and Human Rights has identified six groups as most affected by sport, namely athletes
(including children), workers (involved in construction, supply chains or supporting events), volunteers and officials, communities
close to sport venues (impacted by the supply chain or human rights risks), journalists and fans.

55
Good governance in sports organisations is one of the focal points of the definition of integrity
and affects all other policy areas. The main objective of this policy area is to promote
transparency, accountability, democracy, participation and social responsibility in sports
governing bodies, especially through the establishment of good governance standards and of
monitoring mechanisms. Good governance is a priority policy area. That’s because if there is a
lack of good governance, there is a higher risk that all other areas will be adversely affected.

4. Strengthening measures against the manipulation of sports competitions

This policy area encompasses the fight against manipulation of sports competitions. The
objective is to have a coherent policy aimed at combating and protecting stakeholders, including
athletes, from criminal activities, such as money laundering, organised crime and corruption. It
also aims to preserve the credibility and uncertainty of sports events, the economy of sports and
the betting industry. This policy area should address how to organise and co-ordinate operations
involving not only stakeholders in the field of sports, but also of law enforcement, anti-corruption
and justice.

5. Ensuring an adequate anti-doping policy framework, its implementation and effective

compliance measures

This policy area aims to protect athletes from doping in sport and uphold the integrity of sport
competitions by ensuring that countries implement an effective anti-doping policy at the national
level, as well as comprehensive monitoring and disciplinary processes. It also seeks to promote
prevention and education activities which bring together public authorities from the fields of
public health, education, law enforcement and customs, as well as those responsible for sport.

The UNESCO International Convention Aagainst Doping in Sport reflects this cross-departmental
approach in that it acknowledges the role that sport plays in health, the harm doping causes to
health, and the undermining effect it has regarding the universal principles enshrined in the
International Charter of Physical Education and Sport.

56
 The standards, legislation and regulations mentioned in each of these factsheets are by no means
an exhaustive list, but they give some indication as to the variety of legal texts that exist.

Factsheet 1 - Preserving the rights, safety and security of athletes, spectators, workers and other
groups involved

Policy area Preserving the rights, safety and security of athletes, spectators,
workers and other groups involved
As the three target groups are usually covered by different policies
at the national level, to improve clarity the answers will be divided
by groups.
Why? Preserve the rights, physical integrity, health, safety and security of
The aim of this policy area all participants in sport and sports events, by ensuring high
standards in the organisation of sports events.
Prevent local populations, but also volunteers and workers
(including those working for suppliers) from being collateral victims
of the organisation of sports events.
Who? A) Rights, safety and security of athletes
Stakeholders involved, co- Sports organisations at national, regional and local level
ordination, partnerships Coaches and the athletes’ entourage
Public authorities responsible for sports
Events organising committees
Support services (e.g. first aid organisations such as Red Cross,
emergency physicians, businesses etc)
Sponsors
Athletes
Athletes’ representatives (both recreational and elite)
Officials

B) Rights, safety and security of spectators

Ministries of Interior and public authorities responsible for justice
and of sports
An event’s organising committee
Police and law enforcement agencies
Municipal authorities
Sports organisations at national, regional and local level
Supporters’ organisations
Support services (e.g. first aid organisations such as Red Cross,
emergency physicians, businesses etc)

C) Rights, safety and security of workers and other groups

Ministries of Interior and public authorities responsible for justice,
employment and for sports
Events’ organising committees

57
 Trade unions, employer organisations
Local communities
Sponsors
What? A) Rights, safety and security of athletes
Functions and tasks they have to Work in partnership to make sure occupational rights, health,
fulfil safety and security are guaranteed, particularly in sporting events
B) Rights, safety and security of spectators
Work in partnership in implementing safety, security and service
arrangements for a sporting event
C) Rights, safety and security of workers and other groups
Ensure that the organisers of sports events which benefit from
guarantees or support from public authorities operate in full
compliance with the applicable laws – and with health and safety
standards – and have a solid sustainability concept covering the
economic, social and environmental dimensions
How? A) Rights, safety and security of athletes
The organisation of operations Develop and implement in co-operation with stakeholders such as
universities evidence-based prevention policies including sport-
specific risk assessments on possible injuries to promote the health
and wellbeing of athletes
Develop illness and injury surveillance programmes
Monitor the volume and intensity of training and competition
schedules to ensure a sport-life balance contributing to the
wellbeing of athletes
Implement athletes’, coaches’ and parents’ education programmes
Evaluate and monitor the application of occupational health and
safety standards to athletes, including workers’ competition
legislation in the cases of professional athletes
B) Rights, safety and security of spectators
Implement a multi-agency (public-public and public-private)
approach, ensuring that safety, security and service measures are
balanced, both in terms of physical infrastructures and the safety
management of the event
C) Rights, safety and security of workers and other groups
Involve the relevant public and private stakeholders in the
preparation of the sustainability concept
Be prepared to deal with international stakeholders that will pay all
the more attention to those projects which achieve international
visibility
Request that competition organisers and their suppliers ensure
compliance with the UN Guiding Principles on Business and Human
Rights

Standards

58
Existing applicable international
or national standards
Governmental (laws, A) Rights, safety and security of athletes
governmental bills, international General normative framework -
conventions etc) Protecting Student Athletes From Concussions Act of 2013 (USA):
https://www.govtrack.us/congress/bills/113/hr3532/text
United Nations (UN) Protect, Respect and Remedy Framework, its
Guiding Principles and Declaration
UN Committee on the Rights of the Child’s General Comment No.
16 on State obligations regarding the impact of the business sector
on children’s rights addressed in 2013 to all States that have
ratified the UN Convention on the Rights of the Child
B) Rights, safety and security of spectators
European Convention on Spectator Violence and Misbehaviour at
Sports Events and in particular at Football Matches (ETS No. 120)
Council of Europe Convention on an Integrated Safety, Security and
Service Approach at Football Matches and other Sports Events
(CETS No. 218)
Recommendation Rec (2015)1 of the Standing Committee of the
Spectator Violence Convention (T-RV), as revised in 2019 and
adopted in 2020
ECRI's General Policy Recommendation No.12 on combating racism
and racial discrimination in the field of sport
ECRI’s General Policy Recommendation No. 15 on combating hate
speech
C) Rights, safety and security of workers and other groups
United Nations (UN) Protect, Respect and Remedy Framework, its
Guiding Principles and Declaration
UN Committee on the Rights of the Child’s General Comment No.
16 on State obligations regarding the impact of the business sector
on children’s rights addressed in 2013 to all States that have
ratified the UN Convention on the Rights of the Child
Recommendation CM/Rec(2016)3 on human rights and business
European Social Charter
ILO Points of Consensus on Decent Work in Sport
Private (sports regulations, A) Rights, safety and security of athletes
disciplinary, contractual, Safe Sport International principles
professional standards etc) Safe Sport Code for the US Olympic and Paralympic Movement
FIFA Regulations on the Status and Transfer of Players (article 19
and 19bis: protection of minors)
FIFA Code of Ethics (article 23 on protection of physical and mental
integrity)
FIFA Disciplinary Code (2019 edition, articles 11 and 12)
International Safeguards for Children in Sport

59
 B) Rights, safety and security of spectators
FIFA and UEFA regulations on safety, security and service
Sports Grounds Safety Authority and CEN guidance and standards
C) Rights, safety and security of workers and other groups
IOC Agenda 2020 and IOC Sustainability Strategy
Global Reporting Initiative (GRI) sustainability framework
ISO 20121 standard for sustainable events management
FIFA Statutes
FIFA Human Rights Policy (specific provision on labour rights)

Declarations and statements A) Rights, safety and security of athletes

IOC Consensus Statement on Training the Elite Child Athlete
Joint statement of the European Sectoral Social Dialogue
Committee for Sport and Active Leisure - Declaration on
Safeguarding the Rights of Child Athletes (November 2017)
IOC Athletes’ Rights and Responsibilities Declaration (2018)
World Player Rights Policy (July 2017) which articulates how the
UNGPs are to be applied to sport
Universal Declaration of Player Rights (November 2017)

Implementation
How is this policy implemented A) Rights, safety and security of athletes
at national level? Through which Sharing responsibilities between stakeholders
mechanisms are the relevant Training safety officers
stakeholders involved in the Raising the standards of facilities and services
monitoring and implementation Share relevant know-how and good practices
of the policies? B) Rights, safety and security of spectators
Socio-educative work with spectators
Intelligence management
Training safety officers
Raising the standards of facilities and services
C) Rights, safety and security of workers and other groups
Enacting appropriate legislation
How is this policy co-ordinated A) Rights, safety and security of athletes
or monitored at international Sport organisations self-monitor and self-assess their policies
level? B) Rights, safety and security of spectators

60
 The Standing Committee of the Spectator Violence Convention (T-
RV) ensures the monitoring of compliance with commitments made
by the States Parties
C) Rights, safety and security of workers and other groups
The Centre for Sport and Human Rights is playing a key role to
facilitate multi-stakeholder co-operation in the context of sports
events and to advise the organising entities
Which parts are more difficult to A) Rights, safety and security of athletes
implement? Implementing an effective and holistic health/wellbeing strategy
involving all stakeholders
B) Rights, safety and security of spectators
Implementing an effective multi-agency approach between the
main national stakeholders is a permanent and long-term effort
Ensuring the right balance between the safety, security and service
arrangements is also a major challenge
C) Rights, safety and security of workers and other groups
The social side of the risk assessment and sustainability concept is
more difficult to take into account and evaluate
What are the main obstacles A) Rights, safety and security of athletes
preventing thorough Lack of awareness about/commitment to the international
implementation? standards
Lack of specific know-how
Cultural barriers that prevent co-operation and communication
between stakeholders
B) Rights, safety and security of spectators
Lack of awareness about the international standards
Lack of specific know-how
Cultural barriers that prevent co-operation and communication
between stakeholders
Complacency
Lack of political commitment at national/local levels to adopt
relevant policies and enforce the law
Lack of financial resources
C) Rights, safety and security of workers and other groups
Lack of awareness about the international standards
Lack of specific know-how
Cultural barriers that prevent co-operation and communication
between stakeholders
Which are the existing A) Rights, safety and security of athletes
international or regional IOC
platforms of exchange of Safe Sport International
information and good practices, Centre for Sport and Human Rights
that may serve as benchmarks? FIFA
UEFA

61
 International Safeguarding Children in Sport Initiative

B) Rights, safety and security of spectators

The Standing Committee (T-RV)
SGSA (Sports Grounds Safety Authority)
NFIP Network (National Football Information Points)
FIFA
UEFA
European Leagues
European supporters’ organisations (such as Supporters Direct
Europe and Football Supporters Europe)
C) Rights, safety and security of workers and other groups
Centre for Sport and Human Rights
IOC
FIFA
Commonwealth Games Federation
Current issues

What are the current hot issues A) Rights, safety and security of athletes
regarding the policy area? Sport-specific and repeated traumas/injuries such as concussions
and burnout
Regulation of player training and competition load
Concussion protocols
Application of occupational health and safety standards
Coverage of workers’ compensation legislation
B) Rights, safety and security of spectators
Organised incidents in and around football stadia, in national and
UEFA competitions (namely use of pyrotechnics, fights between
organised groups of supporters or against players or the police) and
lack of physical safety conditions in some sports venues
Complacency in maintaining high safety and security standards
C) Rights, safety and security of workers and other groups
Migrant workers’ rights
What are the main risks that A) Rights, safety and security of athletes
could prevent the Lack of commitment of top management and certain stakeholders
implementation of policies in such as coaches, parents etc
this area? Inadequate development, application and enforcement of
protocols and guidelines to protect athlete health and wellbeing
B) Rights, safety and security of spectators
Insufficient leadership of national public and private authorities in
implementing effective preventative and repressive policies or
enforcing the existing laws and regulations
Reputational damage

62
 Sports governance and integrity
Judicial/administrative burdens in prosecuting troublemakers
C) Rights, safety and security of workers and other groups
Lack of commitment by employers to train their workers and to
enforce rules on how to deal with situations that pose risks
Which human rights would have Freedom from discrimination
to be taken into account and Right to life, liberty and personal security
protected by this policy? (As Freedom from slavery
referred to in the UN Universal Right to remedy by competent tribunal
Declaration of Human Rights) Freedom from arbitrary arrest and exile
Right to social security
Right to desirable work and to join trade unions
What are the main challenges to Signature and ratification of the Convention CETS No. 218 by States
improve the effectiveness of this Improving monitoring mechanisms and strengthening technical
policy? assistance and international co-operation, namely by reinforcing a
peer-to-peer approach
Are there any good practices A) Rights, safety and security of athletes
that may be mentioned? Stop sport injuries https://www.stopsportsinjuries.org/
Talent development and injury prevention in youth alpine ski racers
of a ski boarding school
Training for CPR and first aid for professional basketball players and
administrative and coaching staff of professional teams

FIFA Online Diploma in Football Medicine

https://www.fifamedicinediploma.com/
FIFA Medical Centres of Excellence
https://www.fifa.com/development/medical/about-us/fifa-medical-
centres-of-excellence/index.html
FIFA online injury surveillance tool (first applied during the 2018
FIFA World Cup)
NFL Game Day Concussion Protocol
FIFPro Concussion awareness campaign
https://fifpro.org/news/remove-a-player-with-a-concussion-from-
the-pitch/en/

Slovenia: The national Sports Law defines social responsibility in

sport as a matter of public interest. The Sport Law establishes an
Athletes Ombudsman to act as guardian of athletes and athletes'
support personnel.
B) Rights, safety and security of spectators
Council of Europe’s Recommendation Rec(2015)1 comprises many
best practices in the fields of safety, security and service at sports
events (see: https://www.coe.int/en/web/sport/recommendation-
2015-1)

63
C) Rights, safety and security of workers and other groups
Sustainability Strategies for FIFA World Cups (FWC 2018 Russia,
FWC 2022 Qatar) with specific provisions regarding health & safety,
decent work and safeguarding workers' rights

64
 Factsheet 2 - Preventing and addressing harassment and abuse in sport

Policy area Preventing and addressing harassment and abuse in sport

Why? To ensure the right to a safe and enjoyable sport environment

The aim of this policy area for all those involved in sport activities, while safeguarding them
and preventing inadequate care.

This policy area deals with non-accidental violence33 in sport

through harassment and abuse,34 which cover the following:

• Psychological harassment and abuse

• Sexual harassment and abuse
• Physical abuse and forced physical exertion
• Neglect.

Science shows that psychological abuse is at the core of all other

forms and that athletes can also be perpetrators.

If all athletes regardless of age, sport ability, gender, nationality,

race or ethnicity, social class, education level, sexual orientation
or disability are susceptible to these problems, elite athletes and
vulnerable subgroups such as LGBT+ athletes, ethnic minority
and disabled athletes are more at risk of being victims of
harassment and abuse in sport.

It follows, therefore, that attention should be paid to the

particular risks faced by those groups that are more likely to be
subject to discrimination and abuse.

In particular, the Centre for Sport and Human Rights proposes a

categorisation of groups or populations that may have particular
vulnerabilities in the field of sports and therefore may require
special attention. These include:

• Children
• Human rights defenders
• Women and girls
• LGBTI+

33
Non-accidental violence is used to distinguish between violent behaviour deemed to be a normal part of a game,
from that considered to overstep the ethical mark, i.e. deliberate or non-accidental violence, i.e. maltreatment
through harassment and abuse (Brackenridge 2010)
34
The IOC Consensus Statement: harassment and abuse (non-accidental violence) in sport, 2016

65
 • Migrants, minority and ethnic groups, indigenous people
and historically disadvantaged communities
• Physically and mentally less abled people.
Who? Public authorities and organisations responsible for sport and for
The stakeholders involved, co- child protection
ordination, partnerships Sports organisations at national, regional and local levels
NGOs/organisations combating discrimination on the grounds of
sexual orientation and gender identity, disability, ethnic origin,
etc
Disabled people’s organisations
Project managers and event organisers
Officials
Athletes' representatives (both recreational and elite)
Youth workers, youth leaders
Parents
Coaches, physical education teachers, and other entourage
members such as volunteers, medical staff, physiotherapists, etc
What? Ensure the development of a cohesive and holistic framework
The functions and tasks they based on evidence that should include tools like normative
have to fulfil frameworks, policies, strategies, action plans, procedures,
monitoring and evaluation
Implement a communication strategy to ensure stakeholders and
individuals are aware of this framework
Support capacity-building and provide technical assistance to
plan and implement this framework, such as prevention and
implementation measures
Develop contingency plans or management measures for when
such behaviour occurs
Set up an independent body to handle cases of harassment and
abuse
Initiate and/or support research/studies on harassment and
abuse in sport, in particular prevalence studies
How? Sports organisations, when set up as a not-for-profit
The organisation of the organisation, are bound by the laws and regulations of the
operations private sector (e.g. for non-profit organisations). Internally,
sports organisations develop their own policies, e.g. disciplinary
standards, creating a variety of different policies and rules. Public
authorities can help harmonise those internal private standards
to ensure an overall coherence in this domain.
Public authorities can draw from existing international standards
to develop their own national regulations and/or strategies.
Any standards developed should ensure adherence to other non-
sport regulations, such as privacy acts, official language, etc

66
 National provisions on protection need to include sport, a topic
which is currently often excluded.
Organisations should develop templates (rules, policies) and
prevention programmes that are easy to adapt and to
implement.
They can also establish a round-table, led by public authorities,
where stakeholders can share information and know-how,
exchange good practices and work together in developing
relevant activities such as policies or action plans.
Standards
Existing applicable
international/national
standards/ recommendations
Governmental (laws, United Nations Convention on the Rights of the Child
governmental bills, international United Nations Convention on the Rights of Persons with
conventions etc) Disabilities
Council of Europe Convention on the Protection of Children
against Sexual Exploitation and Sexual Abuse
Council of Europe Convention on preventing and combating
violence against women and domestic violence (2011)
Council of Europe recommendation on measures to combat
discrimination on ground of sexual orientation and gender
identity (2010)
Framework Convention for the Protection of National Minorities
(1994)
Council of Europe Recommendation on gender mainstreaming in
sport (2015)
Council of Europe Recommendation to prevent and combat
sexism (2019)
Private (sports regulations, FIFA Code of Ethics
disciplinary, contractual, FIFA Disciplinary Code (2019 edition, article 13)
professional standards etc) International Safeguards for Children in Sport
Declarations and statements The IOC Consensus Statement: harassment and abuse (non-
accidental violence) in sport (2016)
The IOC Consensus Statement on sexual harassment and abuse
in sport (2007)
Declaration on Safeguarding the Rights of Child Athletes
(November 2017)
WPA Gender Equality Principles (2017)
Universal Declaration of Player Rights

Implementation
How is this policy implemented Through strong international governing bodies such as the IOC
at a national level? Through and through national stakeholders implementing customised

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which mechanisms are relevant national strategies based on recommendations of and/or support
stakeholders involved in the from relevant international platforms such as Safe Sport
implementation and monitoring International
of the policies? Through effective national child protection and safeguarding
legislation which is inclusive of the sporting sphere
By multi-stakeholder meetings enabling the sharing of
challenges, good practices, the development of new ideas and
pilot tests
Through research and know-how, to support prevention and
awareness-raising activities
How is this policy co-ordinated Audit
and monitored at international Annual reports to monitor progress of implementation
level? Statistics on sanctions and on interventions
Which parts are more difficult to The parts that require thorough and on-going monitoring and
implement? compliance. Resources are often insufficient.
Ensuring that existing efforts are effectively monitored and
evaluated
Applying general international principles to local, challenging
contexts where existing social welfare capacity may be under
resourced
Ensuring that monitoring and evaluation strategies are built into
future strategies at the initial planning phase
Screening processes of any person dealing with children and
youth
What are the main obstacles Lack of financial resources
preventing thorough Lack of human resources trained to deal with such cases, and
implementation? frequent turnover of volunteers
Lack of awareness and misconceptions related to the issue of
harassment and abuse in sport (e.g. that harassment and abuse
do not occur in the field of sport, that they only occur in some
sports, or in some countries, etc)
Lack of a sense of responsibility and commitment of top
management
Lack of co-operation among stakeholder organisations and lack
of ownership
Lack of procedures and enforcement
Sports structures and cultures
High tolerance of physical violence and injuries
Authoritarian leadership and an unequal power relationship
between coaches and athletes
Scandal avoidance
Male-dominated gender ratio
Physical contact is often required
Reward structures

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 Inappropriate sexual behaviour is often tolerated, and
discrimination and gender inequality accepted
Several potential risk situations exist: changing rooms, showers,
carpooling, overnight stays, etc
Compliance mechanisms and policies apply only to organised
sport – many people playing sport do so outside these more
formal structures. The proposed activities on preventing and
addressing harassment and abuse have to be transferred to and
applied in self-organised sport.
Current issues

What are the current hot issues Safeguarding of participants in sports, including physical
regarding the policy area? wellbeing, concussion, misuse of substances (e.g. painkillers),
harassment, abuse and discrimination
#MeToo in sport
What are the main risks that There is a ‘fear factor’ regarding:
could prevent the • The perception that sport is unsafe
implementation of policies in • An organisation’s capacity to implement
this area? • Its capacity to respond to disclosures that are likely to
increase when implementing such a policy
• The resources needed
• Ownership of responsibilities
• Too many issues – amid a lack of co-ordination
Which human rights would have Right to life, liberty, personal security
to be taken into account and Freedom from torture and degrading treatment
protected by this policy? (as Right to remedy by competent tribunal
referred to in the UN Universal Right to a fair public hearing
Declaration of Human Rights)
What are the main challenges to Determine the scope and resources needed to achieve the goals
improve the effectiveness of this
policy?
Are there any good practices Sports organisations and other relevant stakeholder
that may be mentioned? organisations have developed several tools to address these
areas. They are often not well-known and a continuous
warehouse of those good practices, co-ordinated with other
approaches, is still needed. An inventory of good practices would
be welcomed.

International; safeguarding for children in sport working group:

International Safeguards for Children in Sport
The international safeguarding for children in sport WG 2 is
currently developing tools to assure the quality of existing
safeguarding resources.

69
Implementing the safeguards for organisations who work with
children.

Council of Europe:
EU-CoE Joint Projects Pro Safe Sport and Pro Safe Sport + (see
the online resource centre, in particular):
Start to Talk initiative
EU-COE joint project ‘ALL IN: towards gender balance in sport /
online library of good practices and resources (to be released in
September 2019).

European Union:
Study on gender-based violence in sport, European Commission
(see the sections on promising and good practices)
Recommendations on the protection of young athletes and
safeguarding children's rights in sport, Expert group on good
governance, European Commission (see Annex 3: Examples of
strategies and good practices)

Resources developed by the CPSU (Child Protection in Sport Unit)

within the UK’s National Society for the Prevention of Cruelty to
Children (NSPCC)

Safeguarding athletes from harassment and abuse in sport, IOC

Toolkit for IFs and NOCs, along with its Athlete Safeguarding e-
learning course and Webinar series

FIFA:
FIFA Child Protection and Safeguarding working group (including
representatives of the Council of Europe and UNICEF):
Development of a dedicated child protection toolkit and training
programme for its 211 member associations

FIFA Good Practice Guide on Diversity and Anti-Discrimination:

https://img.fifa.com/image/upload/wg4ub76pezwcnxsaoj98.pdf

Italy:
Creation of the "National Observatory on Sport Events", with a
brief to carry out analysis activities (including the monitoring and
study of the phenomenon of violence and structural problems in
sports facilities), making regulatory proposals (including the
drafting of directives, promotion of coordinated initiatives with
other stakeholders) and documentation activities (annual
reports).

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 The “Battiamo il silenzio”, a forum within which the Department
of Sport and other institutions and associations promote policies
that aim to ensure that all young athletes, without distinction or
discrimination, can practice sport in a healthy and safe
environment.

Jordan: Adoption of the Prevention of Harassment and Abuse in

Sport Toolkit, involving the provision of regular safe sport
awareness sessions delivered to all sport pillars including
athletes, coaches, sport federation admins, PE teachers and
university students, and awareness sessions about the
Manipulation of Competitions to all athletes, and sport
delegations, coaches, and National Federations.

Factsheet 3 - Fostering good governance of sport organisations

Policy area Fostering good governance of sport organisations

Why? Good governance is seen as the pivotal issue without which no

The aim of this policy area other integrity issue will be properly solved.
The aim of good governance is to promote transparency,
democracy, accountability, participation and societal
responsibility in national and international sports governing
bodies. It creates a solid foundation for building trust, growth
and performance.
Who? Co-ordination is usually ensured either by the public authority in
The stakeholders involved, co- charge of sport or the umbrella sports organisation. It should
ordination, partnerships involve:

• Public authorities responsible for sport

• Sports organisations
• Sponsors
• Anti-Doping Organisations
• Anti-corruption authorities

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 • Media professionals
• Academics
• Civil society organisations addressing issues related to
sport governance and anti-corruption
• Athletes’ representatives (both recreational and elite)
• Fans

What? Agree on minimum principles, standards, benchmarks and

The functions and tasks they monitoring mechanisms
have to fulfil Support the development of internal policies (e.g. on due
diligence, conflicts of interest, gifts and invitations) and
educational programmes
Set up a pool of governance experts for taking positions in sports
organisations (governance advisor, members of ethics
commission)
Establish professional standard Ccodes of Cconduct
Support the implementation of benchmarks by the sports
movement (e.g. with conferences, educational activities,
communication, lobbying, and research projects)
Monitor the implementation, directly (e.g. in cases where
governmental authorities directly collect information on the
implementation of good governance in sports organisations
through reports, audits or questionnaires) or indirectly (e.g.
when governmental authorities entrust an umbrella sports
organisation with making sure organisations comply with good
governance principles and gather information so as to prove
such compliance)
Take corrective measures (including reward for progress and
sanction of failures), which are in line with their competence and
respect freedom of association
How? Co-operative system between governments and umbrella sports
The organisation of the organisations on the division of tasks to ensure co-ordination
operations

Standards
Existing applicable
international/national standards
Governmental (laws, Council of Europe Committee of Ministers’ Recommendation
governmental bills, international CM/Rec(2005)8 on The principles of good governance in sport
conventions etc) Council of Europe Committee of Ministers’ Recommendation
CM/Rec(2018)12 on the promotion of good governance in sport
EU Expert Group on Good Governance: 2013 Principles of Good
Governance of Sport

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 UNESCO Convention Model Strategic Framework (for adoption
during the ninth session of the Conference of Parties in October
2023)

Private (sports regulations, Sports organisations:

disciplinary, contractual,
professional standards etc) • IOC Basic Universal Principles of Good Governance of the
Olympic and Sports Movement
• Olympic Charter
• IOC Agenda 2020
• ASOIF Key Governance Principles and Basic Indicators
• FIFA Statutes (2019 edition)
• FIFA Governance Regulations
• Badminton World Federation Statutes
• World Athletics Governance Rules

Other organisations:

Sports Governance Observer by Play the Game

Sport Integrity Global Alliance universal standards
Implementation
How is this policy implemented With national laws
at national level? Through which Some governments are tying good governance requirements on
mechanisms are relevant sports organisations to public grants or to recognition as national
stakeholders involved in the sports organisations
monitoring and implementation Others entrust or encourage an umbrella sports organisation
of the policies? (e.g. National Sports Confederation or NOC) to conduct the
process
Publication of compliance reports of sports organisations with
the Olympic Charter and national laws
Education and training, e.g. from NOCs and sports
confederations to national federations
How is this policy co-ordinated Direct and indirect monitoring mechanisms by sports
and monitored at international organisations:
level?
Reviews and monitoring mechanism of sports governing bodies
(e.g. IOC’s monitoring of NOCs, EOC EU Office’s SIGGS self-
evaluation tool and POINTS programmes, monitoring activities of
NOCs and national sport governing bodies)
Training programmes such as UEFA’s Hat Trick

Direct and indirect monitoring mechanisms by other

organisations:

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 Academic research and/or benchmarking of governing bodies in
sport by NGOs such as Transparency International (e.g. Sport
Governance Observer studies)
Co-ordination at international level:

Since 2017, the multi-stakeholder platform International

Partnership Against Corruption in Sport (IPACS) has been co-
ordinating dialogue among its partners - sports organisations,
governments and intergovernmental organisations - to create
common tools for the prevention of corruption risks in sport. In
the area of good governance, IPACS aims to promote the
convergence of benchmarks, applicable by national and
international organisations and recognised both by governments
and sports organisations

Direct and indirect monitoring mechanisms by public authorities:

According to the UNESCO Anti-Doping Convention (Article. 20),
States Parties shall encourage relevant competent professional
associations and institutions to develop and implement
appropriate codes of conduct, good practice and ethics related
to anti-doping in sport that are consistent with the World Anti-
Doping Code. States Parties report on the implementation of this
provision as part of the monitoring framework for compliance
purposes.

Which parts are more difficult to A merits-based boardroom, independent board members, small-
implement? size/effective-size board
Overcoming a lack of diversity, excessive standards for travel and
per diem rates, vote-buying in elections, no clear separation of
roles and responsibilities between political and operational
management
Requirements on term limits, financial transparency,
independence of ethical and disciplinary bodies, prevention and
management of conflicts of interest; noting that often the most
suitable persons for governance roles, based on experience and
expertise, are most susceptible to conflicts
Political will to implement good governance reforms
Meaningful involvement of stakeholders, especially athletes
What are the main obstacles Most sports federations, especially at international level, are
preventing thorough eager to avoid external interference, which leads them to a
implementation? mistrust towards good governance reforms, since they are often
promoted by umbrella sports organisations, NGOs or
governmental organisations

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 Many sport federations feel over-challenged and there is a risk of
overloading them with disproportionate (labour and resource
intensive) requirements
Many governments (or their governmental officials) are closely
involved or have interest in sport, i.e. there are many conflicts of
interest
Most governments are hesitant to introduce rules and standards
that affect the inner life of sports organisations. Some may even
turn a blind eye to unethical behaviours
Some governments do not have the appropriate legal provision
to implement due diligence, investigate and sanction private
corruption in sport
Sports organisations can be culturally slow to adapt to the
changing society and to new evolving challenges, both internally
but also in co-operation with external stakeholders
To convince sports organisations, governments, sponsors, media
companies and other key stakeholders that supporting reforms
of sports governance would lead to more efficient organisations
that are better synchronised with the core interests of their
individual athlete members and society at large
Current issues

What are the current hot issues The harmonisation of requirements between governments and
regarding the policy area? sport
The transparent publication of the results of reviews and
research
Avoid overkill by imposing extended nit-picking prescription to
small organisations
Keeping a fair balance between necessary good governance
requirements and the need to respect the autonomy of sports
organisations
What are the main risks that Lack of co-ordination with regards to the different areas of
could prevent the concern
implementation of policies in Lack of constructive co-operation between sports organisations
this area? and public authorities
Too heavy and detailed sets of requirements (exaggerated
measures that infringe association freedom)
Which human rights would have Right to remedy by competent tribunal
to be taken into account and
protected by this policy? (as
referred to in the UN Universal
Declaration of Human Rights)

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What are the main challenges to To consolidate a harmonised set of requirements that are
improve the effectiveness of this recognised and promoted
policy? To develop supporting measures to help sports organisations
implement these standards
To ensure that all the governance of sports organisations is
reviewed and the results published
To develop incentives and sanctions to increase commitment
To introduce a rule that no governmental official/member of
parliament or minister/secretary of state can hold a position in
international sports organisations
Government fear of sanctions by international sports governing
bodies because of undue interference in the internal affairs of
sports organisations
Boards and individuals on boards fear voting themselves out of
office
Are there any good practices EPAS HANDBOOK:
that may be mentioned? Countries like the UK, the Netherlands, Belgium (Flanders), and
Australia have introduced measures that condition public
support towards sport’s implementation of central criteria for
good governance.

International and national sports organisations subjecting

themselves to independent governance reviews, including IOC,
IPC, FIFA, IAAF and World Sailing

ASOIF/AWOIF/GAISF Support and Monitoring Unit to support

their members to improve governance

National sport federations’ adherence to national standards in

Australia, Holland, New Zealand and the UK are monitored by the
public entities overseeing sport. Measures in place include self-
assessment and independent audits.

The International Partnership Against Corruption in Sport (IPACS)

is providing a platform for discussion between sport
organisations, governments and intergovernmental
organisations, with the purpose of setting up exchange of best
practices to mitigate the risk of corruption in sport.

SIGGS of the EOC EU Office

Finland: Sustainability criteria applied to the funding of sport

organisations

76
Lithuania: The Sports Law requires that a code of ethics should
be incorporated into the statutes of national federations
addressing a range of integrity and behavioural standards.

United Arab Emirates: Establishment of a governance

department at the UAE General Authority of Sports, this
department having major role in the adoption across sport of
principles of sports integrity. A key resolution aims to ensure that
sports clubs achieve the goals for which they were established,
enhance their role in serving the community and promote the
principles of sports integrity, transparency, disclosure, and
accountability.

UK: tThe UK Code for Sports Governance sets out the levels of
transparency, diversity and inclusion, accountability and integrity
that are required from those organisations who seek – and are in
receipt of – UK Government and National Lottery funding from
Sport England and/or UK Sport.

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 Factsheet 4 - Strengthening measures against the manipulation of sports competitions

Policy area Strengthening measures against the manipulation of sports

competitions

Why? Tackling sports manipulation allows us to address some of the

The aim of this policy area connected issues, including:

• Preserving the uncertainty of sports competitions

• Protecting sport stakeholders from criminal threats
• Fighting organised crime, money laundering and corruption
linked with manipulation of sport competitions
• Preserving the economy of sports and of sports betting
Who? Public authorities, including law enforcement, justice, anti-
The stakeholders involved, co- corruption, anti-money laundering
ordination, partnerships National regulatory authority of the betting market
Betting industry (public-private operators, monitoring systems)
National sports organisations (NOCs, key sports federations, etc)
Athletes' representatives (both recreational and elite)
Anti-corruption and human rights NGOs

All these national stakeholders have to work together as part of

National Platforms. National Platforms then co-operate at trans-
national levels.
What? The different stakeholders all belong and respond to a National
The functions and tasks they Platform and have different roles and responsibilities in the fields of
have to fulfil prevention, investigation and sanctions. An example of a structure
could be the following:

• Ministry responsible for sport: co-ordination, hotline,

international co-operation
• Betting industry (directly or via regulatory authority):
betting alerts monitoring
• Ministry of Interior: investigation
• NOCs and sport federations, in co-operation with athletes’
representatives: prevention and education within sports
bodies and against sport fraud and prevention of problem
gambling/addiction
• Ministry of Foreign Affairs: international relations related to
sport and corruption

78
How? The activities are conducted autonomously by each entity, but the
The organisation of operations co-ordination and the flows of information are managed by the
National Platform.
Standards
Existing applicable international
or national standards
Governmental (laws, Convention on manipulations:
governmental bills, international
conventions etc) • Council of Europe Macolin Convention

Anti-corruption conventions:

• United Nations Convention against Corruption

• Criminal Law Convention on Corruption
• Convention on Transnational Organised Crime
• The United Nations Convention against Transnational
Organized Crime
Private (sports regulations, Olympic Movement Code on the Prevention of the Manipulation of
disciplinary, contractual, Competitions, which is mandatory for all the Olympic Movement
professional standards etc) International Federations (and part of the Olympic Charter)
Declarations and statements EU Athletes Code of Conduct for Athletes
Implementation
How is this policy implemented Strengthening the co-operation framework among private and
at national level? Through which public bodies, including the exchange of information
mechanisms are relevant Multiplying and upgrading the National Platforms
stakeholders involved in the Develop adequate awareness raising/prevention programs
monitoring and implementation Organising and securing the flows of information
of the policies? Necessity to establish systems able to strengthen trust among each
other

In many countries, the Office for Sport/Ministry has a co-ordinating

role. A strong collaboration with the NOC and sports organisations
is also very important.

79
How is this policy co-ordinated Every second year, the IOC International Forum on Sport Integrity
or monitored at international gathers international stakeholders to co-ordinate the fight against
level? manipulation across the board
The Olympic Movement Unit on Prevention against Manipulation of
Competition, including the mechanism IBIS (Integrity Betting
Intelligence System)
The Convention follow-up, Committee of the Macolin Convention,
will monitor the implementation of the Convention and facilitate
international co-ordination
IOC/INTERPOL/UNODC capacity-building and training programme
to sport organisations and public authorities
Partnership Development Meetings are regularly held in order to
promote the establishment of operational collaboration between
law enforcement, sport and betting regulators and operators
nationally and internationally as well as to help national
stakeholders in setting up co-ordinated platforms to protect the
integrity of sport
Which parts are more difficult to All parts (legislative improvements, protected reporting system,
implement? investigation capacity, training, self-regulation, enhanced betting
monitoring, others) are very complicated and require a dedicated
effort. It’s typically more a matter of stakeholders’ effective
engagement and co-ordination than of specific budget.

Education: The operationalisation of values-based education in the

prevention of the manipulation of competitions. There is a
challenge to ensure that all athletes and athlete support personnel
who are subject to rules on prevention of the manipulation of
competitions are sufficiently informed and understand these rules.
What are the main obstacles Lack of awareness is by far the main obstacle
preventing thorough Lack of long-term vision is a relevant factor as well, since
implementation? preventing sports manipulations are rarely a priority in the short
term
Lack of synergies among different acting bodies and stakeholders
Lack of resources dedicated to the scope

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Which are the existing The Network of National Platforms (Group of Copenhagen)
international or regional launched by the Council of Europe
platforms of exchange of The sectoral networks established by the Council of Europe and
information and good practices international partners: prosecutors, regulators, law enforcement,
that may serve as benchmarks? sports movement, ministries
The AMFF program. www.icamf.it and www.icramf.eu
The Olympic Movement Unit on Prevention of the Manipulation of
Competition, including the mechanism IBIS platform for
international sport organisations
INTERPOL Match-Fixing Task Force
IFSI – International Forum for Sports Integrity
Current issues

What are the current hot issues The fight against illegal betting
regarding the policy area? How to promote the exchange of information while complying with
the secrecy of judicial inquiries, the presumption of innocence and
the protection of personal data
What are the main risks that Lack of prioritising
could prevent the Lack of specialised competencies
implementation of policies in Lack of confidence between stakeholders
this area?
Which human rights would have Right to remedy by competent tribunal
to be taken into account and Freedom from arbitrary arrest and exile
protected by this policy? (as Right to fair public hearing
referred to in the UN Universal Right to be considered innocent until proven guilty
Declaration of Human Rights) Freedom from interference with privacy, family, home and
correspondence
What are the main challenges to Lack of clear understanding of prevention, particularly of the need
improve the effectiveness of this to implement good governance and of protecting athletes’ rights
policy? and welfare to decrease risk of match fixing
Are there any good practices Council of Europe Group of Copenhagen: Alert and Surveillance
that may be mentioned? System

Council of Europe Macolin Roadmap

EOC:
Points project of the EOC EU Office http://www.points-
project.com/: establishment of Single Points of Contact for integrity
topics in the partner organisations

INTERPOL-IOC:
Handbook on protecting sport from competition manipulation

IOC-UNODC:

81
Reporting mechanisms in Sport: A Practical Guide for Development
and Implementation

FIFA:
Integrity department and Integrity Initiative, which adopts an
integrated approach to tackle match manipulation through five key
pillars: prevention, monitoring, information gathering,
investigations, and adjudication
Integrity Officer Kit (e-learning tutorial and practical handbook)
FIFA Specific Recommendations to Combat Match Manipulation -
Guidelines for FIFA member associations (Circular no. 1424).

EU Athletes:
PROtect Integrity education campaign

FIFPro (and others):

Red Button reporting app

ITALY:Italy:
AMFF program http://www.anti-match-fixing-formula.eu
AMATT http://www.anti-match-fixing-top-training.net + T-PREG
training programs
http://www.stop-match-fixing-italia.org

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 Factsheet 5 - Ensuring an adequate anti-doping policy framework, its implementation and
effective compliance measures

Policy area Ensuring an adequate anti-doping policy framework, its

implementation and effective compliance measures

Why? Doping is fundamentally contrary to the spirit of sport and to its

The aim of this policy area universal values.
Anti-doping policies aim at:

• Protecting athletes' health

• Preserving the spirit of sport as the pursuit of human
excellence through the dedicated perfection of each
person’s natural talents
• Preserving the credibility of major sports events
• Ensuring the right to compete on a doping-free, level
playing field
Who? Public authorities in charge of sports
The stakeholders involved, co- Public authorities in charge of public health, education, police and
ordination, partnerships customs
UNESCO
Council of Europe
NADOs
NOCs, NPCs
National Sport Federations and sports clubs
Athletes' representatives (both recreational and elite)
Athletes’ support personnel
Parents and athletes’ entourage
Physical education teachers
National NGOs addressing anti-corruption, human rights and
related issues
International Testing Authority (ITA)
World Anti-Doping Agency (WADA)
Media
What? Implementation by public authorities of their commitments made
The functions and tasks they under the UNESCO and Council of Europe Conventions
have to fulfil The establishment by public authorities of NADOs to assist in the
implementation of Convention commitments
Harmonisation of anti-doping rules and regulations across all sports
and all countries worldwide
Increasing good governance in anti-doping organisations and
institutions, including avoidance of conflicts of interest and
ensuring independence

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 Defining and implementing effective measures against doping in
sport
Public authorities must make available the necessary legal
instruments, national structures, financial and (trained) human
resources
Development and implementation of disciplinary procedures and
measures for people and organisations with regard to prohibited
substances and method
Establishing safe whistle-blowing mechanisms in anti-doping with a
comprehensive policy on the protection of whistle-blowers and
possible victims, and on subsequent investigation power
Continued co-ordination and collaboration among stakeholders in
implementation and further development of the anti-doping rules
Monitor the compliance of anti-doping organisations with
applicable laws, good governance principles and international anti-
doping standards
ITA is in charge of full testing monitoring controls for IFs.The
International Testing Agency (ITA) plans and executes Testing plans
on behalf of many International Federations, as well as providing
advice on compliance and standards.
How? Strategic planning undertaken by public authorities as to the
The organisation of operations implementation by public authorities of their commitments made
under the UNESCO and Council of Europe Conventions
Effective standard setting (developing new or updating the existing
standards) through a stakeholders’ consultation process
Co-ordination of the policies and actions of all stakeholders
concerned with combating doping in sport and support to the
activities of the NADO
Bilateral, regional and specialised co-operation agreements,
thematic conferences and other discussion platforms and events
Monitoring processes using online auto-evaluation tools, evaluation
visits, legal opinions, thematic audits or full-fledged audits of an
anti-doping organisation, database analysis, collection of
information (intelligence) and investigation
Application of appropriate sanctions on non-compliance by sport
organisations
Standards
Existing applicable international
or national standards
Governmental (laws, UNESCO International Convention against Doping in Sports
governmental bills, international Council of Europe Anti-Doping Convention and its Additional
conventions etc) Protocol
UNESCO International Charter of Physical Education, Physical
Activity and Sport

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 National anti-doping laws related to the implementation of anti-
doping program
Council of Europe Anti-Doping Convention

Private (sports regulations, World Anti-Doping Code and International Standards

disciplinary, contractual, IOC, IPC, IF, NOC, NPC, NF governing rules and anti-doping
professional etc) regulations and disciplinary procedures CAS Statutes and Rules of
Procedure
NFL Policy and Program on Substances of Abuse (NFL PPSA)
NHL – NHLPA Substance Abuse and Behavioural Program (NHL
SABP)
NBA-NBPA 2017 – 2024 Collective Bargaining Agreement (NBA
CBA), article XXXIII
Major League Baseball’s Joint Drug Prevention and Treatment
Program, (2016) (MLB JDA)
NHL – NHLPA 2013 – 2022 (NHL CBA), article 47
Implementation
How is this policy implemented The fulfilment by public authorities of their commitments made
at national level? Through which under the UNESCO and Council of Europe Conventions
mechanisms are relevant NADOs are public or private bodies that are empowered (through
stakeholders involved in the delegated authority) by public authorities to undertake activities
monitoring and implementation that Governments have committed to take by way of their
of the policies? commitments under the UNESCO and Council of Europe Anti-
doping Conventions. NADOs also commit to certain roles and
responsibilities stipulated within the Code. implement anti-doping
activities based on the relevant national legislation and national
anti-doping rules. Under the Code, where there is no NADO, the
responsibility lies with the NOC.
Domestic co-ordination networks involving the relevant ministries
and key stakeholders are used for anti-doping activities, both within
(education, testing, information and prevention, data privacy, etc)
and outside the competence of NADO – formal education, health
care, recreational sport, restricting availability of doping
substances.
How is this policy co-ordinated UNESCO, the Council of Europe and WADA have monitoring
or monitored at international mechanisms in place to assess compliance with their respective
level? normative frameworks:

• UNESCO monitors the implementation of the International

Convention against Doping in Sports in its 189 191 States
Parties
• WADA monitors compliance with the Code and Standards in
its 600+ signatories

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 • The Council of Europe evaluates the implementation of the
Anti-Doping Convention in all its 52 States Parties

The three organisations are working together to ensure co-

ordination of the monitoring mechanisms and avoid
duplicationscooperating and sharing relevant information according
to their respective mandates.
Which parts are more difficult to The establishment by public authorities of strategies to implement
implement? their commitments made under the UNESCO and Council of Europe
Conventions. The Operational Guidelines and Model Strategic
Framework produced by the Conference of Parties for the UNESCO
Convention are important resources.
Information sharing between public authorities and anti-doping
organisations due to a lack of legal frameworks
Part of the doping control process is testing and this is resource-
intensive
Disciplinary Process - Due to the complexity of the anti-doping rule
violation cases, it is difficult to ensure high quality review, hearing
and decision-making processes in all ADOs
Education – The operationalisation of preventative values-based
education in anti-doping. There is a challenge to ensure that all
athletes and athlete support personnel subject to anti-doping rules
are sufficiently informed and understand these rules
What are the main obstacles Extensive framework ofLack of harmonized anti-doping standards
preventing thorough Applying the same standards to countries and organisations of
implementation? different size and economic situations
Public authorities’ lack of understanding and experience of anti-
doping programs
Unclear division of roles and responsibilities
Financial restrictions, because of the high costs involved - especially
around the analytical part of the anti-doping programs
Difficulties in accessing formal education systems.
Which are the existing UNESCO in particular:, the Operational Guidelines as to the
international or regional Conventionand Framework for strengthening the implementation
platforms of exchange of of the Convention; the Global Resources Framework: States Parties’
information and good practices Good Practices; the regular regional consultations among National
that may serve as benchmark? Compliance Platforms; and the Model Strategic Framework
(pending adoption)s developed to assist public authorities in
developing their plans for implementing the Convention
CoE
WADA
International Testing Authority (ITA)
iNADO
European Union

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Current issues
What are the current hot issues ADOs’ compliance with the Code and Standards
regarding the policy area? Athletes' involvement including in the governance of anti-doping
Respect for fundamental rights
Controversies on the effectiveness of testing
Governments’ accountability and compliance regarding governance
requirements
What are the main risks that Good governance principles and compliance with anti-doping
could prevent the standards have to be applied consistently across all anti-doping
implementation of policies in organisations in order to ensure equity of athletes’ treatment.
this area? If compliance with the international anti-doping standards can’t be
achieved, the health and rights of athletes as well as the integrity of
sport won’t be protected
Which human rights would have Right to fair public hearing
to be taken into account and Right to be considered innocent until proven guilty
protected by this policy? (as Freedom from interference with privacy, family, home and
referred to in the UN Universal correspondence
Declaration of Human Rights) Right to free movement in and out of the country

What are the main challenges to Insufficient co-ordination of policy implementation (as addressed
improve the effectiveness of this by the legal framework of UNESCO)
policy? Different levels of sophistication between anti-doping programs
both between countries and between sports organisations
Complexity of the rules (Conventions/Code/International
Standards)Balancing Governmental commitments made pursuant
to international Conventions and NADO responsibilities as Code
Signatories
Development of new substances and methods of doping
Development of legislation
Are there any good practices UNESCO:
that may be mentioned? Operational Guidelines and a Framework of Consequences for non-
compliance with the International Convention against Doping in
Sport
https://unesdoc.unesco.org/ark:/48223/pf0000370457

Consideration for the elaboration of the model legislative

framework
https://unesdoc.unesco.org/ark:/48223/pf0000370345 Model
Strategic Framework materials – UNESCO. These provide a
suggested planning platform for a number of key Convention
commitments.

COUNCIL OF EUROPE:
Anti-doping Convention Recommendations:

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 • Information sharing
• Independence of hearing panels
• Independence of NADOs
https://www.coe.int/en/web/sport/adopted-texts-on-anti-doping

WADA Guidelines:
https://www.wada-
ama.org/en/resources/search?f%5B0%5D=field_resource_collectio
ns%3A190

World Players Association:

It is increasingly understood that engagement with athletes,
including through their player associations, is the most effective
way to deliver meaningful anti-doping education - see for example
https://www.tv2.no/a/10416420/
https://www.brisbanetimes.com.au/sport/asada-breaking-down-
overlord-stigma-with-athletes-20190216-p50y8m.html

Colombia:
Within the recertification process of the Anti-Doping Laboratory,
efforts are being added to advance investigative actions with the
aim of promoting better behaviours from collaborative and co-
creative processes with stakeholders and with the National
University of Colombia.

India: Adoption of a national legislative framework for

implementation of anti-doping programme, being the National
Anti-Doping Act 2022.

Malaysia:
• The development of a legal framework by way of the
Develop a legal framework of Malaysian Anti-Doping Agency Act
and the establishment of the National Anti-Doping Organisation,
the Anti-Doping Agency of Malaysia (ADAMAS) as an independent
body under the supervision of the Ministry of Sport.
• The strengthening of cooperation as between ADAMAS and
key stakeholders including the National Olympic and Paralympic
Committee, national sports bodies and government agencies such
as Ministry of Health, Ministry of Education, Ministry of Higher
Education, in relation to anti-doping education and awareness
• The establishment of the independent ADAMAS Advisory
Board to advise, monitor and evaluate ADAMAS in matters related
to the implementation of anti-doping activities.

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Namibia: Promulgation of the first school sport policy which
incorporates anti-doping and integrity issues.

Senegal: Revision of the Code of Sport to endow the NADO with the
rank of agency with administrative and financial autonomy, thereby
ensuring its overall Operational Independence.

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Conclusion

It is hoped that these guidelines will be used to their full potential as a map, a point of reference
and as a source of inspiration for Ministries responsible for sports that are developing sport
integrity policies. They will also be a reminder to the reader of how relevant sport is when it
comes to preserving integrity.

These guidelines contain a snapshot of the situation today. However, we know that the world of
sport and the challenges it faces continue to constantly evolve at pace, and that the
implementation of policies has to adjust and adapt accordingly.

It should therefore be noted that the good practices mentioned in these guidelines and the
standards which set out the legal framework in the various policy areas are, of course, not an
exhaustive list. For this reason, these guidelines are accompanied and completed by an online
directory of many other best practice examples and legal references.

The online directory will be updated in line with the changing landscape of sport, and we
encourage the reader to suggest the addition of any new references (or indeed deletion of
obsolete ones) via the webpage.

https://www.coe.int/en/web/sport/kazan-action-plan-online-directory

With the publication of these guidelines and its associated webpage it is expected that, as a
direct result of the Kazan Action Plan, they will be presented to the MINEPS VII Conference in
20212023 and to the ninth session of the Conference of Parties to the UNESCO International
Convention against Doping in Sport. It is also hoped that other opportunities may be sought to
raise awareness on the guidelines, perhaps during other major events and conferences involving
intergovernmental representatives active in the field of sport.

In addition, activities to support the concrete implementation of the guidelines could be

developed under UNESCO mainstreaming approach, networks and relevant resources, such as
regional training courses, National Compliance Platforms, advisory visits or other creative tools to
help put these guidelines into practice.

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[Back cover blurb]

The Council of Europe is the continent’s leading

human rights organisation. It comprises 47
member states, 28 of which are members of
the European Union. All Council of Europe
member states have signed up to the European
Convention on Human Rights, a treaty
designed to protect human rights, democracy
and the rule of law. The European Court of
Human Rights oversees the implementation
of the Convention in the member states.

www.coe.intEnd cover

Since the Enlarged Partial Agreement on Sport (EPAS)

was set up in 2007, its major priority has been to address
current challenges facing sport in Europe. To this end, it has
developed a pan-European programme involving a variety
of stakeholders from public authorities and the world of
sport. All have an important role to play in reversing the
discriminatory trends currently observed in sport and in
promoting sport as a means of fostering diversity and social
cohesion. As at 1 March 2020, EPAS comprises 38 member states.

https://www.coe.int/en/web/sport/member-states

91