Labour Disputes
Texto da decisão
REF. FPSD-14342
Decision of the
Dispute Resolution Chamber
passed on 22 August 2024
regarding an employment-related dispute concerning the player Ericksson
Patrick Correia Andrade
COMPOSITION:
Frans DE WEGER (The Netherlands) , Chairperson
Oleg ZADUBROVSKIY (Russia), Member
Khadija TIMERA (Senegal), Member
CLAIMANT:
Ericksson Patrick Correia Andrade, Cape Verde
Represented by Jose Miguel Sampaio e Norra
RESPONDENT:
Partizan, Serbia
Represented by Zoran Damjanovic
pg. 2
REF. FPSD-14342
I. Facts of the case
1.
On 1 July 2022, the Cape Verdian player Ericksson Patrick Correia Andrade (hereinafter: the
Claimant or the Player) and the Serbian club Partizan (hereinafter: the Respondent or the
Club) concluded an employment agreement (hereinafter: the Contract), valid from the
aforementioned date until 30 June 2025.
2.
Pursuant to Article 3.1 of the Contract, the Respondent undertook to pay the Claimant inter
alia a net monthly salary of RSD 37,436.14. According to the same Article, “Payment of the
salary for the previous month shall be effected no later than by 30th day of the current month.”
3.
The Respondent further undertook to pay the following amounts to the Claimant:
−
Sign-on fee of EUR 200,000 net
−
Loyalty fee payable during the period in which the Player is under contract (starting
from July 2022 up to June 2025) and in equal monthly instalments of EUR 50,000
net.
4.
The Contract also established that the foregoing amounts were payable in Serbian dinars,
by the middle course of NBS – National Bank of Serbia, on the day of payment.
5.
Under Article 3.3 of the Contract, the parties also stipulated several performance bonuses,
inter alia, a bonus for placement in the UEFA Conference League – group competition phase
in the amount of EUR 50,000 net, in dinar equivalent, at the middle exchange rate of the
NBS on the day of payment, only under the condition that the Player performs in 60% of
the matches in the qualification games as a member of the starting lineup.
6.
Finally, under Article 7 of the Contract, the Respondent agreed to provide the Claimant with
“apartment rental and four return flight tickets per year to Republic of Cabo Verde.”
7.
By correspondence dated 30 May 2023, the Claimant put the Respondent in default of
payment of EUR 275,000 net setting a time limit of 15 days in order to remedy the default
(hereinafter: the Default Notice). The aforementioned correspondence referenced the
following amounts as being unpaid and overdue:
−
−
−
8.
Loyalty fee for February 2023, March 2023, April 2023, and May 2023 (EUR 200,000
net in total)
Prize for qualifying for UEFA Conference League (EUR 50,000 net)
House rent (EUR 25,000 net)
On 13 June 2023, the Respondent replied to the Default Notice, rejecting the Claimant’s
calculations and acknowledging that only the loyalty fees for March 2023 and April 2023
(EUR 100,000) were owed, and that the Claimant was only owed EUR 19,400 in unpaid rent.
pg. 3
REF. FPSD-14342
9.
On 20 June 2023, the Claimant replied to the above correspondence from the Respondent
(hereinafter: the Termination Letter). In this correspondence, the Claimant acknowledged
that he had been paid the loyalty bonus for February 2023 but that he was still owed EUR
225,000, comprised of the following items:
−
−
−
Loyalty fee for March 2023, April 2023, and May 2023 (EUR 150,000 net in total)
Prize for qualifying for UEFA Conference League (EUR 50,000 net), denying that there
was any agreement modifying the due date of this bonus.
House rent (EUR 25,000 net)
10. As such, and considering that the Claimant had granted the Respondent a deadline of 15
days to comply with the requested payment, he considered the requirements of arts. 14
and 14bis to be satisfied and thereby terminated his Contract with immediate effect.
11. On 12 July 2023, the Claimant signed an employment agreement with Qarabag FK in
Azerbaijan, where he currently remains employed. According to said employment
agreement, the Claimant is entitled to a total of USD 500,000 net, payable in the following
manner:
−
−
−
−
USD 30,000 due in July 2023
USD 20,000 due every month between August 2023 and June 2024, inclusive
USD 30,000 due in July 2024
USD 20,000 due every month between August 2024 and June 2025, inclusive
II. Proceedings before FIFA
12. On 9 April 2024, the Claimant filed the claim at hand before FIFA. A summary of the parties’
position is detailed below.
a. Position of the Claimant
13. According to the Claimant’s initial position, The Claimant argued that he is owed EUR
225,000 net in outstanding remuneration – as described in his Termination Letter – as well
as EUR 1,250,000 net corresponding to the remaining amounts under the Contract.
14. On 16 April 2024, in response to a request to complete his claim, the Claimant modified his
request for relief. In essence, the Claimant once again claimed the February 2023 loyalty
fee, in addition to the loyalty fees for March, April and May 2023, as well as the prize for
UEFA Conference League qualification and the housing expenses, for a total of EUR 275,000
net in outstanding remuneration.
pg. 4
REF. FPSD-14342
15. Regarding the compensation for breach of contract, and citing arts. 14 and 14bis of the
FIFA Regulations on the Status and Transfer of Players, the Claimant claimed the remaining
value of the Contract, in addition to the loyalty fee for June 2023 and all of the 2023/2024
and 2024/2025 seasons, for a total of EUR 1,250,000 net.
16. The requests for relief of the Claimant, as amended, were the following:
“a) Consider his unilateral breach with just cause of the Professional Player Contract dealed[sic]
with the Respondent Club, in 20th June 2023;
b) In consequence of that order the Respondent Club to pay immediatly[sic] the Player the net
amount of €275.000 (two hundred seventy five thousand euros) as the amounts already due
and not paid of the article n. 2 of the article 3 of the Professional Player Contract duly attached
as Schedule 2;
c) In consequence of that order the respondent Club to pay immediately[sic] the Player the net
amount of €1.250.000 (one million- and five hundred twenty five euros) as the remaining
amounts and not paid of the article n. 2 of the article 3 of the Professional Player Contract duly
attached as Schedule 2;
d) In consequence also order the Club to pay the Player an interest rate of 5% of any amount
condemned to pay the player per month of delay from the date of due till the date of effective[sic]
payment regarding to the period after the purpose of this claim.”
b. Position of the Respondent
17. In its reply, the Respondent did not dispute the Claimant had just cause to unilaterally
terminate the Contract. However, the Respondent disputed the Claimant’s calculations as
to the outstanding remuneration and compensation for breach of contract.
18. The Respondent argued the Claimant was only owed the loyalty fees for March, April, and
May 2023, in addition to the UEFA Conference League prize and housing reimbursement,
for a total of EUR 219,400. According to the Respondent, the February 2023 fee was paid
out in two payments on 26 and 30 May 2023, and the June 2023 fee was initially allocated
as compensation for breach of contract by the Claimant in his first request for relief and
should remain as such.
19. Regarding the housing reimbursement, the Respondent provided a Rental Agreement and
noted the apartment in question was rented from 1 August 2022 until 30 June 2023 with a
monthly rent of EUR 2,800, for which the Claimant paid or had to pay a total rent of EUR
30,800 over the course of 11 months. In this respect, the Respondent averred having
reimbursed the Claimant for rental costs in the amount of EUR 11,400. Therefore, the
Claimant was only due EUR 19,400 in outstanding housing payments.
20. Furthermore, the Respondent argued that the amount claimed as compensation for
breach of contract was incorrect, and, in any case, must be mitigated with due
consideration for the Claimant’s subsequent employment agreement with Qarabag FK. In
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REF. FPSD-14342
this respect, the Respondent averred that the starting point for calculating the residual
value had to be EUR 1,250,000, which was the value of the Contract from June 2023 through
June 2025.
21. Finally, concerning the interest claimed, the Respondent disputed the application of the
requested 5% per month, arguing that the Claimant was entitled to interest of 5% p.a. as
per the Respondent’s request for relief. Notably, the Respondent argued that the interest
on the compensation for breach of contract shall run from 26 March 2024, referring to this
as the date in which the claim was filed before FIFA.
22. The requests for relief of the Respondent were the following:
“1. To partially accept the Claim of the player Ericksson Patrick Correia Andrade;
2. To order FC Partizan to pay to the Player Ericksson Patrick Correia Andrade:
a) 219.400,00 EUR as outstanding remuneration with corresponding interests as follows:
- 50.000,00 EUR as outstanding loyalty fee for March 2023 with an interest of 5% p.a. as from
01 April 2023 until the date of effective payment;
- 50.000,00 EUR as outstanding loyalty fee for April 2023 with an interest of 5% p.a. as from 01
May 2023 until the date of effective payment;
- 50.000,00 EUR as outstanding loyalty fee for May 2023 with an interest of 5% p.a. as from 01
June 2023 until the date of effective payment;
- 50.000,00 EUR as outstanding bonus for placement in the UEFA Conference League group
competition phase in season 2022/23 with an interest of 5% p.a. as from 01 January 2023 until
the date of effective payment;
- 19.400,00 EUR as outstanding rent with an interest of 5% p.a. as from 29 May 2023 until the
date of effective payment;
b) Compensation for breach of contract in the amount to be nominally determined by the
Dispute Resolution Chamber but equal to the difference between residual value of the contract
with FC Partizan (1.250.000,00 EUR) and value of new contract with FC Qarabag for the period
corresponding to the time remaining on the prematurely terminated contract with FC Partizan,
plus corresponding interest of 5% p.a. as from 26 March 2024 until the date of effective payment.
3. To reject any and all further claims of the player Ericksson Patrick Correia Andrade.”
c. Respondent’s unsolicited correspondence
23. On 17 June 2024, the FIFA general secretariat informed the parties of the closure of the
submissions phase. Nonetheless, on 4 July 2024, the Respondent filed unsolicited
comments.
24. Thereafter, on 31 July 2024, the FIFA general secretariat acknowledged receipt of the
Respondent’s correspondence and informed it that this correspondence had been
submitted after the closure of the submission phase and that it would be up to the relevant
chamber of the Football Tribunal to accept or reject such correspondence (cf., art. 23, par.
1 of the Procedural Rules).
pg. 6
REF. FPSD-14342
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
25. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or DRC) analysed
whether it was competent to deal with the case at hand. In this respect, it took note that
the present matter was presented to FIFA on 9 April 2024 and submitted for decision on 22
August 2024. Taking into account the wording of art. 34 of the March 2023 edition of the
Procedural Rules Governing the Football Tribunal (hereinafter: the Procedural Rules), the
aforementioned edition of the Procedural Rules is applicable to the matter at hand.
26. Furthermore, the Chamber referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (June 2024 edition), the Dispute
Resolution Chamber is competent to deal with the matter at stake, which concerns an
employment-related dispute with an international dimension between a Cape Verdian
player and a Serbian club.
27. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 26 par. 1
and 2 of the Regulations on the Status and Transfer of Players (June 2024 edition), and
considering that the present claim was lodged on 09 April 2024, the February 2024 edition
of said regulations (hereinafter: the Regulations) is applicable to the matter at hand as to
the substance.
b. Burden of proof
28. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider
evidence not filed by the parties, including without limitation the evidence generated by or
within the Transfer Matching System (TMS).
c. Merits of the dispute
29. Having established the competence and the applicable regulations, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all
the above-mentioned facts as well as the arguments and the documentation on file.
However, the Chamber emphasised that in the following considerations it will refer only to
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REF. FPSD-14342
the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Admissibility of the Respondent’s unsolicited correspondence
30. The Chamber first noted that the Respondent submitted unsolicited comments after the
closure of the submission phase in the present case. Nevertheless, the Chamber referred
to the clear and unambiguous wording of art. 23 par. 1 of the Procedural Rules, finding that
these comments were inadmissible and should be disregarded.
ii. Main legal discussion and considerations
31. The Chamber then moved to the substance of the matter, and took note of the fact that
the present matter concerns a claim for outstanding remuneration and compensation for
breach of contract following the Claimant’s unilateral termination of the Contract, citing
just cause. The Chamber further noted that it was undisputed among the parties that the
Claimant had just cause to terminate the Contract.
32. In this context, the Chamber acknowledged that, considering the facts of the case, the
formal requirements of art. 14bis par. 1 were in any event satisfied. In particular, the
Chamber highlighted the fact that the parties appeared to agree that the loyalty fees in
question were understood by all as part of the Claimant’s total monthly remuneration for
his services, of which more than two months were acknowledged by both parties to be
overdue, in addition to the fact that the Claimant had notified the Respondent in writing of
its default and granted at least 15 days to fully comply with its financial obligations.
33. Therefore, the Chamber concurred that the Claimant had just cause to terminate the
Contract.
iii. Consequences
34. Having stated the above, the Chamber turned its attention to the question of the
consequences of the undisputed unjustified breach of contract committed by the
Respondent.
35. The Chamber observed that the outstanding remuneration at the time of termination,
coupled with the specific requests for relief of the Player, are equivalent to three monthly
loyalty fees (i.e., March, April and May 2023) under the Contract, amounting to EUR 150,000.
The Chamber reasoned that, while the Claimant also claimed the February 2023 loyalty fee
as outstanding remuneration, the Respondent provided proof of payment corresponding
to this amount and the Claimant, in his letter dated 20 June 2023, acknowledged receipt of
the February 2023 loyalty fee.
pg. 8
REF. FPSD-14342
36. Moreover, the Chamber noted that it was undisputed among the parties that not only were
the loyalty fees for March, April, and May 2023 due to the Claimant, but also the EUR 50,000
net bonus for the Respondent’s placement in the UEFA Conference League group
competition phase, was owed to the Claimant.
37. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Chamber decided that the Respondent is liable to pay to the Claimant the amounts
which were outstanding under the Contract at the moment of the termination, i.e., EUR
200,000 net.
38. Concerning the claimed housing payments, the Chamber noted that the Claimant did not
elaborate on his claim, limiting himself to stating that he was owed EUR 25,000 for his
housing expenses under Article 7 of the Contract. In this sense, the Chamber recalled that
the Contract did not stipulate an exact amount for a housing allowance or reimbursement
and the Claimant did not provide proof to substantiate his calculations. Conversely, the
Chamber recalled that the Respondent provided a Rental Agreement representing a total
rent amount of EUR 30,800, as well as payment proofs amounting to EUR 11,400 for a
partial reimbursement of rent to the Claimant. Thus, according to the Respondent, only
EUR 19,400 remained outstanding as housing payments to the Claimant.
39. Hence, on the basis of the evidence in the file and the general legal principle of pacta sunt
servanda, the Chamber decided to award the Claimant EUR 19,400 to the Claimant.
40. In addition, taking into consideration the Claimant’s request as well as the constant practice
of the Chamber in this regard and the Respondent’s acknowledgements in this regard, the
latter decided to award the Claimant interest at the rate of 5% p.a. on the outstanding
amounts as follows:
•
•
•
•
•
5% interest over the amount of EUR 50,000 net as from 1 April 2023 until the date of
effective payment;
5% interest over the amount of EUR 50,000 net as from 1 May 2023 until the date of
effective payment;
5% interest over the amount of EUR 50,000 net as from 1 June 2023 until the date of
effective payment;
5% interest over the amount of EUR 50,000 net as from 1 January 2023 until the date of
effective payment;
5% interest over the amount of EUR 19,400 as from 29 May 2023 until the date of
effective payment.
41. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable to the player by the club in the case at stake. In doing so, the
Chamber firstly recapitulated that, in accordance with art. 17 par. 1 of the Regulations, the
amount of compensation shall be calculated, in particular and unless otherwise provided
for in the contract at the basis of the dispute, with due consideration for the law of the
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REF. FPSD-14342
country concerned, the specificity of sport and further objective criteria, including in
particular, the remuneration and other benefits due to the player under the existing
contract and/or the new contract, the time remaining on the existing contract up to a
maximum of five years, and depending on whether the contractual breach falls within the
protected period.
42. In application of the relevant provision, the Chamber held that it first of all had to clarify as
to whether the pertinent employment contract contained a provision by means of which
the parties had beforehand agreed upon an amount of compensation payable by the
contractual parties in the event of breach of contract. In this regard, the Chamber
established that no such compensation clause was included in the employment contract at
the basis of the matter at stake.
43. As a consequence, the members of the Chamber determined that the amount of
compensation payable by the club to the player had to be assessed in application of the
other parameters set out in art. 17 par. 1 of the Regulations. The Chamber recalled that
said provision provides for a non-exhaustive enumeration of criteria to be taken into
consideration when calculating the amount of compensation payable.
44. Bearing in mind the foregoing as well as the claim of the player, the Chamber proceeded
with the calculation of the monies payable to the player under the terms of the Contract
from the date of its unilateral termination until its end date. In this sense, the Chamber
recalled the Claimant requested EUR 1.250.000 as compensation for breach of contract,
representing the loyalty fees for June 2023 and the entirety of the 2023/2024 as well as the
2024/2025 seasons. Notably, the Claimant did not request or even mention the net
monthly salary of RSD 37.436,14 stipulated in art. 3.1 of the Contract. Therefore, the
Chamber could not take these amounts into consideration (ne ultra petita).
45. The Chamber further underscored that, by the same token, the Respondent concurred in
the foregoing initial calculation of the residual value of the Contract (EUR 1,250,000)
without taking into account the salary in art. 3.1 of the Contract, and additionally requested
that it be mitigated based on the value of the Claimant’s new contract.
46. Consequently, the Chamber concluded that the amount of EUR 1,250,000 serves as the
basis for the determination of the amount of compensation for breach of contract.
47. In continuation, the Chamber verified as to whether the player had signed an employment
contract with another club during the relevant period of time, by means of which he would
have been enabled to reduce his loss of income. According to the constant practice of the
DRC as well as art. 17 par. 1 lit. ii) of the Regulations, such remuneration under a new
employment contract shall be taken into account in the calculation of the amount of
compensation for breach of contract in connection with the player’s general obligation to
mitigate his damages.
pg. 10
REF. FPSD-14342
48. Indeed, the Claimant found employment with Qarabag FK. In accordance with the pertinent
employment contract, the Claimant was entitled to approximately EUR 462,425 (USD
500,000). Therefore, the Chamber concluded that the Claimant mitigated his damages in
that amount.
49. Subsequently, the Chamber referred to art. 17 par. 1 lit. ii) of the Regulations, according to
which a player is entitled to an amount corresponding to three monthly salaries as
additional compensation should the termination of the employment contract at stake be
due to overdue payables. In the case at hand, the Chamber confirmed that the contract
termination took place due to said reason i.e., overdue payables by the club, and therefore
decided that the player shall receive additional compensation.
50. In this respect, the DRC decided to award the amount of additional compensation of EUR
150,000, i.e., three times the monthly remuneration of the player.
51. Consequently, on account of all of the above-mentioned considerations and the
specificities of the case at hand, the Chamber decided that the Respondent must pay the
amount of EUR 937,575 to the Claimant (i.e., EUR 1,250,000 minus EUR 462,625 plus EUR
150,000), which was to be considered a reasonable and justified amount of compensation
for breach of contract in the present matter.
52. Lastly, taking into consideration the Claimant’s request as well as the constant practice of
the Chamber in this regard, the latter decided to award the player interest on said
compensation at the rate of 5% p.a. as of 20 June 2023 until the date of effective payment.
iv. Compliance with monetary decisions
53. Finally, taking into account the applicable Regulations, the Chamber referred to art. 24 par.
1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA
deciding body shall also rule on the consequences deriving from the failure of the
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
54. In this regard, the DRC highlighted that, against clubs, the consequence of the failure to
pay the relevant amounts in due time shall consist of a ban from registering any new
players, either nationally or internationally, up until the due amounts are paid. The overall
maximum duration of the registration ban shall be of up to three entire and consecutive
registration periods.
55. Therefore, bearing in mind the above, the DRC decided that the Respondent must pay the
full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, a ban from
registering any new players, either nationally or internationally, for the maximum duration
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REF. FPSD-14342
of three entire and consecutive registration periods shall become immediately effective on
the Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
56. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
57. The DRC recalled that the above-mentioned ban will be lifted immediately and prior to its
complete serving upon payment of the due amounts, in accordance with art. 24 par. 8 of
the Regulations.
d. Costs
58. The Chamber referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Chamber decided that no procedural costs were to be
imposed on the parties.
59. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
60. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
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REF. FPSD-14342
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Ericksson Patrick Correia Andrade, is partially accepted.
2.
The Respondent, Partizan, must pay to the Claimant the following amount(s):
- EUR 19,400 as outstanding remuneration plus 5% interest p.a. as from 29 May 2023
until the date of effective payment;
- EUR 200,000 net as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount EUR 50,000 net of as from 1 April 2023 until the date
of effective payment;
- 5% interest p.a. over the amount EUR 50,000 net of as from 1 May 2023 until the date of
effective payment;
- 5% interest p.a. over the amount EUR 50,000 net of as from 1 June 2023 until the date of
effective payment;
- 5% interest p.a. over the amount EUR 50,000 net of as from 1 January until the date of
effective payment;
- EUR 937,575 net as compensation for breach of contract plus 5% interest p.a. as from
20 June 2023 until the date of effective payment.
3.
Any further claims of the Claimant are rejected.
4.
Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.
5.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid. The maximum duration of the ban shall
be of up to three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
in the event that full payment (including all applicable interest) is still not made by the
end of the three entire and consecutive registration periods.
pg. 13
REF. FPSD-14342
6.
The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
7.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
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REF. FPSD-14342
NOTE RELATED TO THE APPEAL PROCEDURE:
According to article 57 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf. article 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
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396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 15