Training Compensation
Texto da decisão
Decision of the
Dispute Resolution Chamber
passed in Zurich, Switzerland, on 16 April 2009,
in the following composition:
Slim Aloulou (Tunisia), Chairman
Theo van Seggelen (The Netherlands), member
David Mayebi (Cameroon), member
Philippe Diallo (France), member
Zola Majavu (South Africa), member
on the claim presented by the club
F,
as Claimant
against the club
C,
as Respondent
regarding training compensation
for the player M
I.
Facts of the case
1.
The player, M (hereinafter: the player), was born on 22 June 1989.
2.
According to the player passport provided by the D Football Association
(hereinafter: DFA), the player was registered for the D club, F (hereinafter: the
Claimant), as from 9 April 2003 until 25 August 2005 as an amateur. Equally,
according to the DFA, the Claimant is a category 3 club and the sporting season in
D runs from 1 July until 30 June of the following year.
3.
On 18 August 2005, the player and the E club, C (hereinafter: the Respondent),
concluded a so called “Scholarship Agreement”, providing, inter alia, for a
duration as from 18 August 2005 until 30 June 2007 and stipulating an allowance
of 90 per week from 18 August 2005 to 30 June 2006 and of 100 per week from 1
July 2006 to 30 June 2007 to be paid by the Respondent to the player.
4.
According to The Football Association (hereinafter: The FA), the player was
registered for the Respondent on 25 August 2005. The Respondent is a category 1
club. The FA equally informed FIFA that the player had not been registered for the
Respondent as a professional.
5.
On 13 September 2007, the Claimant lodged a claim in front of FIFA and claimed
from the Respondent its proportion of the training compensation in connection
with the player, amounting to a total of EUR 84,583, i.e. EUR 2,083 for the period
of 9 April 2003 until 22 June 2003, EUR 10,000 for the period of 23 June 2003 to 22
June 2004, EUR 60,000 for the period of 23 June 2004 to 22 June 2005 and EUR
12,500 for the period of 22 June 2005 to 13 September 2005, plus interest of
5 % p.a. on the aforementioned total amount as of 13 October 2005 until the
effective date of payment.
6.
In its response, the Respondent held that no training compensation at all or,
alternatively, training compensation amounting to EUR 33,369 was owed to the
Claimant. According to the Respondent:
-
the claim lodged by the Claimant is time-barred in accordance with art. 25
par. 5 of the Regulations for the Status and Transfer of Players (edition 2005;
hereinafter: the Regulations);
-
the Claimant never offered a contract, as provided for in art. 6 par. 3 of Annex
4 of the Regulations and;
-
in the event the Dispute Resolution Chamber would not reject the claim in its
entirety, the Respondent would, alternatively, have to be ordered to pay to
the Claimant training compensation amounting to EUR 33,369 only, since the
calculation of the amount allegedly owed was not performed correctly by the
Claimant.
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7.
Pertaining to the foregoing, the Respondent asserts that the player was registered
for it at The FA on 25 August 2005 and that from this moment on, since the
registration of the player for the Respondent at The FA is the event giving rise to
the present dispute, the Claimant would have had time during two years in order
to file its claim before FIFA against the Respondent. However, following the
Respondent’s arguments, the Claimant only lodged the claim in front of FIFA on
13 September 2007, thus 20 days after the two-years time-frame pursuant to art.
25 par. 5 of the Regulations elapsed. Therefore, the Respondent holds that the
DRC should dismiss the Claimant’s claim.
8.
In case the DRC should not follow this aforementioned primary argument of the
Respondent, the latter holds that the claim must in any event fail due to the
provisions of art. 6 of Annex 4 of the Regulations. In this context, the Respondent
points out, in particular, that art. 6 par. 3 of Annex 4 of the Regulations is
applicable to cases involving clubs located in countries within the EU and obliges
the former club to offer the player a new contract irrespective of the fact whether
the player was registered as a professional or as an amateur for his former club.
Therefore, the Claimant should only be entitled to receive training compensation
in connection with the player if it proves that it had offered the player a contract.
9.
Alternatively, the Respondent asserts that, in the unlikely event that the DRC
concludes that the Claimant has satisfied the burden upon it under the
aforementioned provision to justify an entitlement to training compensation, the
amount of training compensation to be paid to the Claimant by the Respondent is
EUR 33,369, consisting of EUR 2,027 for the period of 9 April 2003 until 22 June
2003 (74 days), EUR 10,000 for the period of 23 June 2003 to 22 June 2004 (12
months), EUR 10,000 for the period of 23 June 2004 to 22 June 2005 (12 months)
and EUR 11,342 for the period of 22 June 2005 to 24 August 2005 (69 days), and
not EUR 84,583, as alleged by the Claimant. Equally, and with regard to the
interest of 5 % claimed by the Claimant as of 13 October 2005, the Respondent is
of the opinion that training compensation is not payable for the reasons set out
above and that it had made the Claimant aware of its position on a number of
occasions before and after the Claimant submitted its statement of claim and that,
given the Claimant’s long delay in commencing a claim, the Respondent does not
think it reasonable or just for the Claimant now to claim interest on any training
compensation which may be payable to the Claimant.
10.
In its reply to the Respondent’s response, the Claimant contests the arguments put
forward by the Respondent in their entirety.
11.
With regard to the first argument of the Respondent, the Claimant holds that, in
any event, the claim was lodged in time, i.e. on 13 September 2007, hence, within
the time frame of two years as from the event giving rise to the dispute, i.e. 30
days after the player was registered for the Respondent at The FA, date on which
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the training compensation in question actually fell due for payment, and that
therefore this argument of the Respondent fails to refute the Claimant’s claim.
12.
Furthermore, and with regard to the second argument of the Respondent, the
Claimant stated, also referring to the jurisprudence of the DRC and the CAS as
well as to the ratio legis of the Regulations and to the Commentary on the
Regulations, that a professional contract had only to be offered to the player if he
already had concluded a professional contract with the former club, and that in
the present case the player was registered for the Claimant as an amateur, reason
for which the Claimant was, according to the Regulations and the Commentary on
the Regulations, not obliged to offer the player a professional contract in order to
secure its right to training compensation. Equally, the Claimant holds that clubs, as
itself, which do not have the necessary financial basis to offer their young players
a professional contract, should not be excluded from receiving training
compensation due to their restricted financial means, this also being in line with
the jurisprudence of CAS.
13.
Pertaining to the above, and in case the DRC should not follow the foregoing
argumentation, the Claimant holds that it demonstrated its “bona fide and
genuine interest” in a further cooperation with the player at the time of his
transfer to the Respondent. In this respect, as a matter of proof, the Claimant
provided FIFA with an undated statement of its chairman, Mr J, declaring that: “F
football club hereby confirms that M was a part of the club’s plans for the future,
both as a player in F’s elite youth team and subsequently at senior elite level, in F’s
first senior team.” Equally, the Claimant enclosed a statement of the player dated
7 November 2008, by means of which he declares the following: “[…] in the
period of time from April 2003 to September 2005, I played on the best F junior
team, that – in that connection – I was part of the club’s elite junior team, and
that during the above period of time – including the time immediately prior to my
contract conclusion with C– I received unmistakable indications from the club that
I was a part of their plans for the future in both the elite junior team and the
club’s first senior team and that the club thus in every way wished to continue
cooperation in future […]”.
14.
Furthermore, the Claimant states that, as appears from the player’s passport, the
player has since his return from the Respondent been registered as a professional
player with the Claimant, which would only be a natural consequence of the
latter’s original wish to retain the player.
15.
With regard to the foregoing, the Claimant equally states that it would conflict
with the primary intention of the provisions in the Regulations regarding training
compensation, “if the club should be entitled to compensation for its major effort
only if it was able to offer a contract to the player in question” and also, in
accordance with the “Den Haag decision […], it would thus be contrary to
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common sense to conclude that my client was not at all interested in keeping the
Player any longer”.
16.
Furthermore, and bearing in mind that, based on the foregoing the claim has to
be accepted, the Claimant holds with regard to the amount to be paid in terms of
training compensation, that the player turned 16 years in the season 2004/2005
and that therefore the indicative amount on which the calculations have to be
based is EUR 60,000, leading to an overall amount of training compensation of
EUR 84,416 to be paid to the Claimant. Finally, regarding the Respondent’s
argumentation with regard to the applicable period of time in connection with
the default interest claimed, the Claimant states that the Respondent had
knowledge of its duty to pay training compensation to the Claimant and that the
latter expected the respective payment to be performed as early as of February
2006. Therefore, the Claimant insists in the comments it submitted in its claim with
regard to the applicable period of time pertaining to the payment of default
interest.
17.
In its extra position, the Respondent, basically, adhered to its previous position.
18.
With regard to the question of the claim being time-barred, it referred to its
response and added that from the Regulations it clearly and undoubtedly
emanates that the event giving rise to the present dispute was the date of the
registration of the player at The FA, and not the date the alleged and contested
payment of training compensation fell due. Therefore, according to the
Respondent, the DRC should dismiss the Claimant’s claim based on art. 25 par. 5
of the Regulations.
19.
In the event that the DRC should not dismiss the Claimant’s claim due to the time
elapsed as set out above, the Respondent states, in addition to what it already
submitted in its response, that notwithstanding the fact that the player was
registered as an amateur for the Claimant, the latter should have offered the
player a contract or at least have shown a bona fide interest and genuine attempt
to keep the player, since, according to the jurisprudence of CAS, “[…] the first
sentence of Article 6 para. 3 of Annex 4 to the 2005 Transfer Regulations does
cover both amateur and professional players”. In this context, the Respondent
further held that the evidence submitted by the Claimant, this is, the statement of
the chairman of the Claimant and of the player, who, when submitting his
statement of November 2008, was again playing for the Claimant, were not
proving that the preconditions pursuant to art. 6 par. 3 of Annex 4 of the
Regulations were fulfilled, since it is logical that the chairman of the club as well
as the player, who is again under contract with the Claimant, would provide
statements in favor of the Claimant, which, however, could not be regarded as
statements of an independent source and that the DRC will for sure take this into
consideration when evaluating the evidence produced. On account of the
foregoing, the Respondent submits that the claim has to be rejected.
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20.
Finally, pertaining to the calculation of the amount of training compensation to
be paid to the Claimant, if the DRC were of the opinion that the claim is not timebarred and that the Claimant has proven a bona fide and genuine interest in
retaining the player, as well as with regard to the default interest claimed, the
Respondent referred to its position submitted in its response.
II.
Considerations of the Dispute Resolution Chamber
1.
First of all, the Dispute Resolution Chamber analysed whether it was competent to
deal with the matter at hand. In this respect, the Chamber first referred to art. 21
par. 2 and 3 of the Rules Governing the Procedures of the Players’ Status
Committee and the Dispute Resolution Chamber (edition 2008). The present
matter was submitted to FIFA on 13 September 2007, thus before the
aforementioned Rules entered into force on 1 July 2008. Therefore, the Dispute
Resolution Chamber referred to art. 18 par. 2 and 3 of the Rules Governing the
Procedures of the Players’ Status Committee and the Dispute Resolution Chamber
(DRC) (hereinafter: Procedural Rules; edition 2005) and concluded that the 2005
edition of the Procedural Rules is applicable to the matter at hand.
2.
Subsequently, the members of the Chamber referred to art. 3 par. 1 of the
Procedural Rules, which states that the Dispute Resolution Chamber shall examine
its jurisdiction in the light of art. 22 to 24 of the Regulations on the Status and
Transfer of Players. In accordance with art. 24 par. 1 in connection with art. 22 lit.
d) of the aforementioned Regulations, the Dispute Resolution Chamber shall
adjudicate on disputes relating to training compensation. As a consequence, the
Dispute Resolution Chamber has, basically, jurisdiction to decide on the present
litigation involving two clubs affiliated to two different associations regarding a
dispute concerning training compensation.
3.
Furthermore, the Chamber analysed which edition of the Regulations on the
Status and Transfer of Players should be applicable as to the substance of the
matter. In this respect, the Chamber referred, on the one hand, to art. 26 par. 1
and 2 of the Regulations on the Status and Transfer of Players (edition 2008) and,
on the other hand, to the fact that the present claim was lodged in front of FIFA
on 13 September 2007 and that the player was transferred to the Respondent on
25 August 2005 (cf. no. I./4. above). In view of the foregoing, the Dispute
Resolution Chamber concluded that the 2005 edition of the Regulations for the
Status and Transfer of Players (hereinafter: the Regulations) is applicable to the
matter at hand as to the substance.
4.
The applicable regulations and, also, basically, the jurisdiction of the DRC being
established, the members of the Chamber started by acknowledging the facts of
the case as well as the documentation contained in the file.
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5.
In this regard, the Chamber first of all drew its attention to the Respondent’s
argument according to which the Claimant’s claim would allegedly be barred by
the statute of limitations in application of art. 25 par. 5 of the Regulations.
6.
The contents of art. 25 par. 5 of the Regulations stipulate that “[…] the Dispute
Resolution Chamber […] shall not hear any case subject to these Regulations if
more than two years have elapsed from the event giving rise to the dispute […]”.
7.
In view of the quoted provision, the Chamber had to define which are “the events
giving rise to the dispute” and duly noted that the Respondent holds that the
event giving rise to the dispute is the registration of the player for the Respondent
at The FA on 25 August 2005.
8.
Bearing in mind the foregoing, the Chamber referred to art. 3 par. 1 of Annex 4 of
the Regulations, which stipulates that, when a player is registering as a
professional for the first time, the club for which the player is being registered, is
responsible for paying training compensation within 30 days of registration (of
the player) to every club for which the player was registered (in accordance with
the players’ career history as provided in the player passport) and that has
contributed to his training starting from the season in which the player had his
12th birthday. In this context, the DRC further recalled the contents of art. 3 par. 2
of Annex 4 of the Regulations, according to which “[…] the deadline for payment
of Training Compensation is 30 days following the registration of the Professional
with the New Association”.
9.
Consequently, according to the Chamber, the Claimant’s possible claim for
training compensation against the Respondent arose on the thirty-first day after
the player was registered for the Respondent at The FA and the Respondent did
effectively not comply with its possible obligation to pay training compensation.
In other words, until the thirtieth day after the registration of a player for his new
club at the new Association, no event giving rise to a dispute would have occurred
and, consequently, no claim could have arisen since until that point in time the
player’s new club would still have the possibility to fulfil its obligation as provided
for by the relevant provisions of the Regulations.
10.
On account of all of the above, the Chamber came to the conclusion that the
event giving rise to the dispute occurred on 25 September 2005, i.e. 31 days after
the registration of the player for the Respondent at The FA, reason for which the
Claimant’s claim cannot be declared barred by the statute of limitations in
application of art. 25 par. 5 of the Regulations, since the claim was lodged on 13
September 2007, thus within the time limit of 2 years, which elapsed on
25 September 2007.
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11.
This being established, and entering into the substance of the matter, the
Chamber continued to assess the further prerequisites to be fulfilled in order for
the Claimant to be entitled to receive training compensation. In this context, the
Chamber stated that, as established in art. 20 of the Regulations in combination
with art. 1 par. 1 of Annex 4 and art. 2 of Annex 4 of the Regulations, training
compensation is payable, as a general rule, for training incurred between the ages
of 12 and 21 when a player is registered for the first time as a professional before
the end of the season of the player’s 23rd birthday.
12.
In this respect, the Chamber recalled that the player was born on 22 June 1989
and was registered for the Claimant as from 9 April 2003 until 25 August 2005 as
an amateur, date on which he was registered at The FA for the Respondent.
13.
Moreover, the Chamber referred, in particular, to art. 6 of Annex 4 of the
Regulations, which contains special provisions regarding players moving from one
Association to another one inside the territory of the European Union
(EU)/European Economic Area (EEA).
14.
In view of the above, the Chamber stated that, first and foremost, it had to verify
whether art. 6 par. 3 sent. 1 of Annex 4 of the Regulations applies in the present
case as lex specialis, and, in the affirmative, to determine if the Claimant had
complied with the said provision in order to be entitled to training compensation.
15.
As far as the applicability of art. 6 par. 3 of Annex 4 of the Regulations is
concerned, the Chamber first of all stated that, as the player moved from D to E in
August 2005, i.e. between two EU countries, art. 6 par. 3 of Annex 4 of the
Regulations is applicable in the present affair. This fact does not appear to be
contested by any of the parties. Therefore, the Chamber concluded that the
aforementioned provision applies in the case at hand as lex specialis.
16.
Equally, the Chamber recalled that the Respondent contested the Claimant’s
entitlement to receive any training compensation arguing, inter alia, that the
Claimant did not offer the player a contract in accordance with art. 6 par. 3 of
Annex 4 of the Regulations and did not show a bona fide and genuine interest in
retaining the player for the future.
17.
On account of the foregoing, the Chamber analysed if the Claimant had complied
with the prerequisites of art. 6 par. 3 of Annex 4 of the Regulations in order to be
entitled to training compensation, this being the core issue of the present dispute.
18.
In this context, the Chamber referred to art. 6 par. 3 sent. 1 of Annex 4 of the
Regulations, which stipulates that, if the former club does not offer the player a
contract, no training compensation is payable unless the former club can justify
that it is entitled to such compensation. Equally, according to art. 6 par. 3 sent. 2
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of Annex 4 of the Regulations, the former club must offer the player a contract in
writing via registered mail at least 60 days before the expiry of his current
contract.
19.
To that regard, the Chamber examined the allegations of the Claimant.
20.
In doing so, the Chamber first of all recalled that in accordance with its wellestablished jurisprudence, which was confirmed by the Court of Arbitration for
Sport (CAS), art. 6 par. 3 sent. 1 of Annex 4 of the Regulations is applicable to both
amateur and professional players (cf. Decision of the Dispute Resolution Chamber
of 27 April 2006, no. 461185, consideration no. II./10. et sq. and CAS 2006/A/1152
Av/N FC, considerations no. 8.6 et sqq.). In fact, according to the Chamber’s
jurisprudence and as confirmed by the CAS in the relevant decision, the second
and third sentence of the provision in question, however, do only apply “to
situations when a professional contract is already in existence, setting out certain
requirements which the training club must meet in order to retain a right to
compensation if a player moves to another club” (cf. point 8.9 of the
aforementioned CAS-decision).
21.
With regard to the Claimant’s argument according to which the Commentary on
the Regulations would stipulate that art. 6 par. 3 sent. 1 of Annex 4 is applicable
in cases where the player was already registered as a professional with the
training club only, the Chamber recalled that, predominantly, commentaries on
regulations or other legislation are utilities to facilitate the interpretation of the
relevant provisions but do not constitute a source of (regulatory) law and can,
consequently, not be concurrent to provisions contained in regulations or the
legislation. This is, the language of a provision governs its interpretation where
the language is clear and explicit and does not involve an ambiguity or absurdity.
In this context, the Chamber pointed out that, in accordance with the
aforementioned decision of the CAS (cf. considerations no. 8.8) as well as the
DRC’s well-established jurisprudence concerning the interpretation of art. 6 par. 3
sent. 1 of Annex 4, the wording of the said provision is absolutely unambiguous
and there is no room for (deviating) interpretation by means of a commentary,
reason for which the Claimant’s argumentation in this respect cannot be upheld.
22.
On account of the above, the members of the Chamber lent emphasis to the fact
that, by virtue of art. 6 par. 3 sent. 1 of Annex 4 of the Regulations, a training club
has to offer a contract to the relevant player in order to have its right for training
compensation preserved, notwithstanding the fact whether or not the player is
registered as an amateur or a professional for the respective training club.
23.
Furthermore, the Chamber specified that according to its jurisprudence, art. 6 par.
3 sent. 1 of Annex 4 of the Regulations, i.e. the obligation to offer a professional
contract to the player, does not apply to pure amateur clubs, which are per se not
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in a position to do so, but does definitively apply to clubs which have both
amateur and professional players registered for them. In this context, the
Chamber recalled that the Claimant has both amateur and professional players
registered for it (cf. I./14. above) and thus concluded that art. 6 par. 3 sent. 1 of
Annex 4 of the Regulations applies to the Claimant.
24.
Also in this respect, the members of the Chamber recalled that it is uncontested by
the parties that the Claimant had never offered a contract to the player before
the latter was transferred to the Respondent in August 2005. Consequently, the
Chamber only had to analyse if the Claimant could justify that it is nevertheless
entitled to training compensation.
25.
In this context, the Chamber took due note that the Claimant asserted that even
though it had not offered a contract to the player and should the DRC conclude
that art. 6 par. 3 sent. 1 of Annex 4 of the Regulations would be applicable as to
the matter at hand, it would still be entitled to receive training compensation
since it showed a bona fide and genuine interest in retaining the player, which
would justify the Claimant’s entitlement to training compensation. Equally, the
DRC acknowledged that, in order to corroborate this fact, the Claimant submitted
an undated statement signed by its chairman, Mr J , and a statement signed by the
player, dated 7 November 2008, by means of which both of the aforementioned
persons declared that the club was very much interested in continuing the
cooperation with the player (cf. I./13. above for the exact wording of the
respective statements).
26.
To that regard, the Chamber, also referring to the aforementioned CAS decision as
well as to art. 12 par. 3 of the Procedural Rules, first of all noticed that the burden
of proof to demonstrate any justification to receive training compensation
notwithstanding not having offered a contract to the player, i.e. a bona fide and
genuine interest of the Claimant in retaining the player, lies with the Claimant (cf.
also consideration no. 8.11 of the aforementioned decision of the CAS). Equally,
the members of the Chamber recalled, according to the well-established
jurisprudence, that this justification is limited to very exceptional circumstances.
27.
Bearing in mind the foregoing remarks, the Chamber analysed the allegations of
the Claimant with regard to the bona fide and genuine interest it showed to
further retain the player.
28.
In this respect, the Chamber noted that, as a matter of proof, the Claimant firstly
produced an undated copy of a declaration of the Respondent’s chairman, Mr J,
stating that “F club hereby confirms that M was a part of the club’s plans for the
future, both as a player in F’s elite youth team and subsequently at senior elite
level, in F’s first senior team.” as well as a statement of the player dated
7 November 2008, by means of which the latter declares the following: “[…] in the
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period of time from April 2003 to September 2005, I played on the best F junior
team, that – in that connection – I was part of the club’s elite junior team, and
that during the above period of time – including the time immediately prior to my
contract conclusion with C – I received unmistakable indications from the club that
I was a part of their plans for the future in both the elite junior team and the
club’s first senior team and that the club thus in every way wished to continue
cooperation in future […]”.
29.
In this respect, the members of the Chamber considered, bearing in mind art. 12
paras. 3 and 6 of the Procedural Rules, that these statements per se, along with no
further documentary evidence, could not be considered as sufficient in order to
establish unambiguously that the club had had a bona fide and genuine interest
in continuing the cooperation with the player.
30.
In this regard, and taking into account the fact that the said declarations were
signed by persons firmly connected to the Claimant and thus not independent
from it in connection with the present matter, the Chamber declared that these
documents did not constitute sufficient documentary evidence to corroborate the
allegations of the Claimant, i.e. the Claimant’s bona fide and genuine interest in
retaining the player. Indeed, the Chamber was of the opinion that it is highly
likely that declarations of the chairman of a club as well as of a player who is
employed by the same club, basically, testify facts in favour of the said club. This,
with regard to the club’s chairman’s statement, due to the fact that he would
most probably be interested in the club’s reward of training compensation and,
with regard to the player’s statement, due to the fact that a player who is
employed by a club would most probably not declare facts to the disadvantage of
his employer since he usually is the subordinate party to an employment contract.
31.
In light of the foregoing, the Chamber concluded that, by failing to produce
evidence of having met the requirements in accordance with art. 6 par. 3 sent. 1 in
fine of Annex 4 of the Regulations, the Claimant is not entitled to receive training
compensation from the Respondent for the transfer of the player.
32.
Finally, and taking into account the above, the members of the Chamber deemed
that the other questions brought up by the parties to the present dispute could
stay open, since one of the cumulative prerequisites in order for the Claimant to
be entitled to training compensation was not complied with.
33.
In view of all of the above, the Dispute Resolution Chamber rejected the claim of
the Claimant.
***
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III.
Decision of the Dispute Resolution Chamber
The claim of the Claimant, F, is rejected.
***
Note relating to the motivated decision (legal remedy):
According to art. 63 par. 1 of the FIFA Statutes, this decision may be appealed against
before the Court of Arbitration for Sport (CAS). The statement of appeal must be sent
to the CAS directly within 21 days of receipt of notification of this decision and shall
contain all the elements in accordance with point 2 of the directives issued by the CAS,
a copy of which we enclose hereto. Within another 10 days following the expiry of the
time limit for filing the statement of appeal, the appellant shall file a brief stating the
facts and legal arguments giving rise to the appeal with the CAS (cf. point 4 of the
directives).
The full address and contact numbers of the CAS are the following:
Court of Arbitration for Sport
Avenue de Beaumont 2
1012 Lausanne
Switzerland
Tel: +41 21 613 50 00
Fax: +41 21 613 50 01
e-mail: [email protected]
www.tas-cas.org
For the Dispute Resolution Chamber
Jérôme Valcke
Secretary General
Encl.
CAS directives
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