Governance Pillar

Compliance, anti-bribery and anti-corruption

Objective: Embed a culture of compliance with a focus on legal and regulatory requirements and adherence to FIFA, FIFA World Cup Qatar 2022 LLC (Q22) and the Supreme Committee for Delivery & Legacy (SC) policies and procedures.

Context

Effective governance and management practices were critical to the successful delivery of the tournament with integrity and in compliance with internal and external requirements, including ethical business practices; human rights, anti-bribery and anti-corruption policies; and national and international laws.

Each of the three delivery partners, FIFA, Q22 and the SC, implemented their own compliance, anti-bribery and anti-corruption systems. Q22 – a joint venture with FIFA - mirrored FIFA’s compliance programme while adapting to the specific needs of the local market.

The compliance, anti-bribery and anti-corruption material topic aligns with the following UN SDG:

Initiatives

The compliance anti-bribery and anti-corruption objective was addressed through the four initiatives summarised below and described in detail on the compliance management web page of this report.

  1. Compliance risk assessment and management
    Identifying and continuously monitoring compliance obligations, defining key risk activities as well as mitigating controls and establishing action plans. Embedding a culture of compliance and implementing a compliance management structure with dedicated resources across the organisations of the primary delivery partners. This also includes setting the tone from the top to communicate the importance of ethics and compliance.

  2. Compliance policies and procedures
    Defining transparent, accessible, and understandable policies and procedures across the organisations, including a code of conduct, code of ethics, anti-bribery and corruption policy, sanctions and export control policy, gifts and entertainment policy, conflict of interest policy, investigation policy, procurement policy and any other policies and regulations that may be applicable in line with generally recognised rules of good governance.

  3. Compliance training
    Providing consistent and effective training, identifying audiences using a targeted risk-based approach. Defining training needs and a tailor-made training plan as well as evaluating training effectiveness and modifying content based on emerging risks.

  4. Compliance performance monitoring and testing
    Implementing robust controls to ensure that compliance teams can enforce and monitor adherence to policies and procedures and provide appropriate and timely mitigation. Performing due diligence for, as well as managing and auditing, third-party and other relationships. Providing systems to monitor and report on the effectiveness of the compliance programme.