Compliance management

The FIFA Statutes, Code of Conduct and Code of Ethics provide the basic laws for world football and members of the FIFA family, including officials, employees, players and associations, and set out FIFA’s standards for ethical business practices. FIFA particularly specifies its human rights commitment in Article 3 of the FIFA Statutes as well as in FIFA’s Human Rights Policy, which is binding on all FIFA bodies and officials. To ensure a separation of power, the independent Ethics Committee, established as the third judicial body under the FIFA Code of Ethics, is responsible for watching over the entire football community and helping to tackle issues in football such as illegal betting, bribery and other prohibited activities. Under the Code of Ethics, disciplinary sanctions can be imposed on offending officials, players, players’ agents and match agents. FIFA has continuously adapted governance mechanisms over past years in order to meet the evolving needs of the modern game and ensure that its operations and values adhere to the best governance standards possible.

Since the inception of Q22, the Management Board has adopted various policies. These include a Code of Ethics and Conduct covering areas such as anti-bribery and corruption, gifts and hospitality, and conflict of interest policies. Other policies cover areas such as procurement, sustainability, complaints handling, finance and data protection. As internal capabilities developed, Q22 has been implementing compliance risk assessments, trainings and monitoring systems since 2020. All Q22 employees are required to undergo mandatory compliance training. In February 2020, the Q22 Legal and Compliance team held a ‘Compliance Week’ where, over the course of a week, a series of Pocket Guides which summarised Q22’s compliance policies were circulated to all Q22 employees. Reference to these Compliance Pocket Guides as well as the Code of Ethics and Conduct Policy is incorporated within the Q22 Employee Handbook.

Also, in 2020, the SC updated its Standards of Conduct Policy which sets out the high standards of compliance and ethical business conduct expected from all employees at the SC. It includes policies on anti-bribery and corruption, anti-discrimination and equal opportunities, and whistle-blowing and non-retaliation, as well as information on the mechanisms in place to report on non-compliances, such as an anonymous hotline and dedicated compliance email address. All employees are required to acknowledge reading and understanding the core values of conduct set out in this document. Additionally, the SC has developed a grievance mechanism for each policy and has expanded the available reporting channels via an easy-to-use project disclosure portal.