Dispute Resolution Chamber
Texto da decisão
REF FPSD-102
Decision of the
Dispute Resolution Chamber
passed on 20 May 2021
regarding an employment-related dispute concerning the player TATOS Andreas
COMPOSITION:
Geoff Thompson (England), Chairman
Michele Colucci (Italy), member
Pavel Pivovarov, (Russia), member
CLAIMANT:
TATOS Andreas, Greece
Represented by Mr Paraskevas Atlamazoglou
RESPONDENT:
Altay Sports Club, Turkey
Represented by Mr Emre Kocak
Page 2 of 14
REF FPSD-102
I.
FACTS OF THE CASE
1.
On 18 January 2019, the Greek player, Andreas Tatos (hereinafter: “the player” or “the
Claimant”) and the Turkish club, Altay Sports Club (hereinafter: “the club” or “the
Respondent”) signed an employment contract (hereinafter: “the first contract”) valid from
18 January 2019 until 31 May 2020.
2.
On 29 January 2020, the parties signed an amendment to the first contract (hereinafter:
“the agreement”) modifying the remuneration of the player.
3.
Point III. 2 of the agreement provided: “Guarantee fee of the player in the 2019-2020
Football Season has been replaced and from now it will be 270,000 Euros. 41,000 Euros of
270,000 Euros were paid, and the remaining guarantee fee of the player for the 2019-2020
season is 229,000 Euros”.
4.
The guarantee fee amounting to EUR 229,000 will be paid by the club as follows:
1) EUR 45,800 on the date of signature of the agreement;
2) EUR 31,600 with a check due on 31 March 2020;
3) EUR 31,600 with a check due on 15 May 2020;
4) EUR 60,000 on 30 June 2020;
5) EUR 60,000 in 4 equal instalments of EUR 15,000 each as monthly salary payable on
February, March, April and May 2020 (first week of each month);
6) EUR 12,000 in 4 equal instalments of EUR 3,000 each as accommodation for the months
of February, March, April and May 2020.
5.
On 30 January 2020, the parties signed a new employment contract (hereinafter: “the
second contract”) valid from 1 June 2020 until 31 May 2021.
6.
Article 3 of the second contract stated that the player is entitled to receive from the club the
total amount of EUR 270,000 as remuneration payable as follows:
1) EUR 50,000 on 31 August 2020,
2) EUR 30,000 on 31 October 2020;
3) EUR 30,000 on 31 December 2020;
4) EUR 40,000 on 28 February 2021;
5) EUR 20,000 on 30 May 2021;
6) EUR 100,000 as monthly wage of EUR 10,000 for ten months beginning from 1 June
2020 until 1 May 2021 payable in the first week of each month,
7) Turkish Lira (TRY) 3,000 as rental payment from June 2020 until May 2021;
8) EUR 10,000 as bonus if the player plays eight matches and above in the first 11 matches
in the TFF 1st League competition and
9) EUR 10,000 as bonus if the player scores ten or more goals in the TFF 1st league
competition in the 2020/2021 season.
Page 3 of 14
REF FPSD-102
7.
By correspondence dated 8 July 2020, the Claimant put the Respondent in default of
payment of EUR 172,000 (i.e. EUR 60,000; EUR 12,000 and EUR 100,000 as outstanding
remuneration [cf. terms agreed in the agreement and the second contract] granting 15 days
to remedy the default (cf. art. 14bis of the RSTP), to no avail.
8.
The player informed FIFA having signed an employment contract with the Greek club, Xanthi
FC, valid from 29 September 2020 until 30 June 2022.
9.
On 5 November 2020, the Single Judge of the Players´ Status Committee authorized the
provisional registration of the player for his new club.
10.
According to said contract with Xanthi FC, the player was entitled to receive the following
remuneration:
a) EUR 870 as monthly salary payable no later than the end of each month, for 12 months
a year;
b) Half of the player´s salary as Christmas gift;
c) Half of the player´s salary as Easter gift;
d) EUR 148,237.50 net payable in 11 instalments as follows: 1) EUR 4,000 on 30 September
2020; 2) EUR 4,000 on 31 October 2020; 3) EUR 4,000 on 31 January 2021; 5) EUR 4,000
on 31 March 2021; 6) 20,000 on 31 July 2021; 7) EUR 3,000 on 31 August 2021; 8) EUR
34,079.16 on 31 October 2021; 9) EUR 3,000 on 31 January 2022; 10) EUR 34,079.16
on 31 March 2022 and 11) EUR 34,079.18 on 31 May 2022.
II.
PROCEEDINGS BEFORE FIFA
11.
On 10 August 2020, the Claimant filed the claim at hand before FIFA. A brief summary of
the position of the parties is detailed in continuation.
a.
12.
The claim of the Claimant
On 10 August 2020, the player lodged the present claim against the club requesting the
payment of EUR 172,000 as outstanding remuneration plus interest as from the respective
due dates. The requested amount is composed as follows:
EUR 60,000 as monthly salaries related to the months from February until May 2020 (cf.
the agreement);
EUR 12,000 as accommodation related to the months from February until May 2020 (cf.
the agreement);
EUR 100,000 as remuneration payable on 1 June 2020 (cf. the second contract).
13. In addition, the player requested the payment of the total amount of EUR 290,000 as
compensation for the contractual breach by the club based on the second contract, which
is composed as follows:
Page 4 of 14
REF FPSD-102
1) EUR 170,000 as the second contract´s instalments (i.e. EUR 50,000 due on 31 August
2020; EUR 30,000 due on 31 October 2020; EUR 30,000 due on 31 December 2020;
EUR 40,000 due on 28 February 2021 and EUR 20,000 due on 30 May 2021);
2) EUR 100,000 as monthly salary (i.e. EUR 10,000 payable each month from 1 June 2020
until 1 May 2021) in accordance with the second contract;
3) EUR 10,000 as bonus if the player has between 8 and 11 participations in football matches
of season 2020-2021 and
4) EUR 10,000 as bonus if the player achieves 10 or more goals in football season 20202021.
14.
The player requested FIFA to declare the second contract unilaterally terminated with just
cause due to outstanding salaries owed by the club as described above.
15.
FIFA administration replied to the player´s request informing, “Either party to an employment
contract between a professional player and a club may terminate the contract if they deem
to have a just cause for such a termination. In case of a dispute, it would be up to the
competent decision-making body to establish whether a contractual breach occurred, with
or without just cause, who is to be deemed responsible and what the consequences of such
a breach would be (cf. article 17 of the Regulations)”.
16.
Furthermore, the player held that all payment agreed between the parties in the different
contracts were in EUR and not in TRY with the only exception of the rental allowance. The
player further argued that the payments provided by the club were all in TRY.
17.
Moreover, the player stated that many of the payments submitted by the club were made
to a person named “Metin Cetin” and not to the player for a total amount of TRY 390,000
(i.e. TRY 120,000 + TRY 270,000). The player further added, “390,000 should not count on
us, as they are not for us but executed by the Club as a commission fee to my manager”.
18.
The player further stated that the club did not provide a detailed reference to each payment
allegedly made.
19.
The player presented a detailed list of the payments invoked by the club indicating that the
club provided copy of payments made from 17 December 2018 until 10 June 2020 for a
total amount of TRY 592,771 allegedly equivalent to EUR 96,616.40.
20.
The player held, “(…) instead of paying the Player an amount of 270.000 euro, it paid only
96.616,40 as analyse in our application. Beyond 10.06.2020 no more payments were made
by the Club (…) considering the above, the Club did not pay the amounts stipulated in the
amendment and the employment contract and, therefore, is in breach of the above”.
b.
Position of the Respondent
Page 5 of 14
REF FPSD-102
20.
The club confirmed having signed on 18 January 2020 an employment contract with the
player and held not having any debt towards the player until his termination without just
cause. In this respect, the club enclosed a list of payments written in Turkish language.
21.
The club requested to dismiss the claim of the player.
III.
CONSIDERATIONS OF THE DISPUTE RESOLUTION CHAMBER
a.
Competence and applicable legal framework
1.
First of all, the Dispute Resolution Chamber (hereinafter also referred to as “the Chamber”
or “the 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 10 August 2020 and
submitted for decision on 20 May 2021. Taking into account the wording of art. 21 of the
2021 edition of the Rules Governing the Procedures of the Players’ Status Committee and
the Dispute Resolution Chamber (hereinafter: “the Procedural Rules”), the aforementioned
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
and observed that in accordance with art. 24 par. 1 in combination with art. 22 lit. a) and
b) of the Regulations on the Status and Transfer of Players (edition February 2021), 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 Greek player
and a Turkish club.
3.
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 Player (edition February 2021), and
considering that the present claim was lodged on 10 August 2020, the June 2020 edition
of said regulations (hereinafter: “the Regulations”) is applicable to the matter at hand as to
the substance.
b.
Burden of proof
4.
The Chamber recalled the basic principle of burden of proof, as stipulated in art. 12 par. 3 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 DRC stressed the wording of
art. 12 par. 4 of the Procedural Rules, pursuant to which it may consider evidence not filed
by the parties.
5.
In this respect, the Chamber also recalled that in accordance with art. 6 par. 3 of Annexe 3
of the Regulations, FIFA’s judicial bodies may use, within the scope of proceedings
pertaining to the application of the Regulations, any documentation or evidence generated
or contained in TMS.
Page 6 of 14
REF FPSD-102
c.
6.
Merits of the dispute
The competence of the DRC and the applicable regulations having been established, the
DRC entered into the merits of the dispute. In this respect, the DRC started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the DRC emphasised that in the following considerations
it will refer only to the facts, arguments and documentary evidence, which it considered
pertinent for the assessment of the matter at hand.
i. Main legal discussion and considerations
7.
The foregoing having been established, the Chamber moved to the substance of the matter,
and took note that the parties confirmed having an employment relationship from January
2020.
8.
In this respect, the Chamber pointed out that the Respondent confirmed having signed an
employment contract with the Claimant on 18 January 2020.
9.
What is more the DRC recalled that the Respondent held that “From the beginning of the
employment relation, the Club acted in line with the employment law and rules. The Club
made all the payments on due dates and had no overdue and unpaid debt towards the
Player until the termination date”.
10.
At this stage, the DRC analyzed the evidence at disposal and pointed out that:
on 18 January 2019, the parties signed the first contract which was valid until 31 May
2020;
on 29 January 2020, the parties signed the agreement and
on 30 January 2020, they concluded the second contract valid until 31 May 2021.
11.
The Chamber highlighted that even if the Respondent referred in its reply to a wrong date
for the second contract, it did not contest specifically the existence and validity of the three
aforementioned documents. In addition, the DRC stated that the club in its reply confirmed
having an employment relationship with the player and argued not having any overdue
payables towards him.
12.
In light of the above, the DRC concluded that the parties signed the three aforementioned
documents, i.e. the first contract, the amendment and the second contract and hence they
have an employment relationship valid until 31 May 2021.
13.
In continuation, the Chamber acknowledged that when lodging his claim before FIFA, the
Claimant requested the DRC to declare terminated the employment relationship with the
Respondent in accordance with art. 14bis of the Regulations and to declare the latter liable
to pay compensation for breach of contract.
Page 7 of 14
REF FPSD-102
14.
In this respect, the Chamber was of the opinion that by lodging, on 10 August 2020, the
present claim against the Respondent before FIFA after sending the default notice to the
latter, the Claimant terminated the employment relationship with the Respondent.
15.
In view of the foregoing and of the diverging opinions of the parties, the DRC held that the
issue at stake considering the argumentation of both parties, was to determine whether
the employment relationship had been unilaterally terminated by the player with or without
just cause on 10 August 2020, and which party was responsible for the early termination.
16.
The DRC also underlined that, subsequently, if it would find that one of the parties breached
the employment relationship, it would be necessary to determine the consequence for the
party that caused the unjust breach of the relevant employment contract.
17.
At this stage, the DRC focused its attention to the Respondent´s allegation by means of
which it stated not having any overdue payables towards the Claimant.
18.
In this respect, the Chamber pointed out that the documentary evidence provided by the
Respondent was written in Turkish and not translated into one of the official FIFA languages
(English, French, German or Spanish) in accordance with art. 9 par. 1 of the Procedural
Rules. Moreover, the Chamber noted that the Respondent did not provide any further
specification regarding said alleged payments.
19.
As a result, the DRC stated that this deciding body should disregard the untranslated
evidence presented by the Respondent.
20.
In this context, the Chamber was keen to emphasise that the basic principle of burden of
proof, as stipulated in art. 12 par. 3 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.
21.
Bearing in mind the foregoing, the Chamber underlined that the club bore the burden of
proving that it indeed paid the amounts due to the player in accordance with the
amendment and the second contract or that it had a valid reason not to have done so.
22.
In addition, the Chamber noted that the Claimant had put the Respondent in default of
payment on 8 July 2020, for the payment of more than two monthly salaries (i.e. four
monthly salaries, accommodation and additional payment) granting the Respondent 15
additional days to remedy the default (cf. art. 14bis of the Regulations), without receiving a
reply from the club.
23.
The Chamber, also noted that, on 10 August 2020, upon the player´s request, the
employment relationship was declared terminated by him. In this regard, the Chamber
observed that the player invoked art.14bis of the Regulations and claimed that the club had
still not paid the relevant outstanding remuneration.
Page 8 of 14
REF FPSD-102
24.
In continuation, the DRC referred out the content of art. 14bis par. 1 of the Regulations,
which, inter alia, stipulates that, in case a club unlawfully fails to pay a player at least two
monthly salaries on their due dates, the player will be deemed to have had a just cause to
terminate his contract, provided that he has put the debtor club in default in writing and
has granted it a deadline of at least 15 days to fully comply with its financial obligations.
25.
Bearing in mind the foregoing, the DRC noted a) that the player acted in accordance with
art. 14bis of the Regulations, b) that after the default notice the club did not pay the
outstanding remuneration and c) that the termination of the contract occurred on 10 August
2020, i.e. more than 15 days after the default notice was given. Thus, the DRC concluded
that the player had a just cause to terminate the employment relationship with the club.
26.
As a result, the DRC decided that the club is to be held liable for the early termination of the
employment relationship with just cause by the player.
ii. Consequences
27.
Having stated the above, the members of the Chamber turned their attention to the
question of the consequences of such unjustified breach of contract committed by the
Respondent.
28.
Having established that the club is to be held liable for the early termination of the
employment relationship, the DRC focused its attention on the consequences of such
termination. Taking into consideration art. 17 par. 1 of the Regulations, the DRC established
that the player is entitled to receive from the club compensation for breach of contract, in
addition to any outstanding payments based on the agreement and the second contract.
29.
Along those lines, the DRC referred to the player’s request regarding outstanding
remuneration at the time of the termination of the contract. In this respect, the DRC
concurred that the club must fulfil its obligations as per the contract in accordance with the
general legal principle of “pacta sunt servanda”.
30.
At this stage, the DRC reiterated that the Respondent did not present any conclusive
evidence proving the payment of the requested remuneration to the Claimant.
31.
Consequently, and bearing in mind that the player terminated the contract on 10 August
2020, the DRC decided that the club is liable to pay to the player the following outstanding
remuneration:
EUR 60,000 as monthly salaries related to the months from February until May 2020
(cf. the agreement);
EUR 12,000 as accommodation related to the months from February until May 2020
(cf. the agreement);
EUR 20,000 as outstanding remuneration related to the months of June and July 2020
(cf. the second contract) and
Page 9 of 14
REF FPSD-102
Turkish Lira (TRY) 6,000 as “rental payment” corresponding to the months of June and
July 2020 (cf. the second contract).
32.
In addition, taking into consideration the specific request of the player, the DRC decided to
award the latter interest at the rate of 5% p.a. on the aforementioned amounts as from the
relevant due dates and until the date of effective payment.
33.
Moreover, and taking into consideration art. 17 par. 1 of the Regulations, the DRC decided
that the player is entitled to receive compensation for breach of contract from the club.
34.
In continuation, the Chamber focused its attention on the calculation of the amount of
compensation for breach of contract due to the player by the club in the case at stake. In
doing so, the DRC 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 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.
35.
In application of the relevant provision, the DRC held that it first of all had to clarify whether
the pertinent employment contract contained any clause, by means of which the parties had
beforehand agreed upon a compensation payable by the contractual parties in the event of
breach of contract. In this regard, the DRC observed that the contract does not contain any
such clause.
36.
As a consequence, the members of the DRC determined that the amount of compensation
payable by the club to the player had to be assessed in application of the parameters set out
in art. 17 par. 1 of the Regulations.
37.
Bearing in mind the foregoing, the DRC proceeded with the calculation of the monies
payable to the player under the terms of the second contract as from its termination and
concluded that the player would have been entitled to receive EUR 250,000 as remuneration
had the employment contract been executed until its regular expiry date, i.e. 31 May 2021.
38.
In continuation, the DRC verified as to whether the Claimant 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.
39.
In respect of the above, the DRC noted, that following the early termination of the second
contract at the basis of the present dispute, the Claimant was able to find new employment
which the club Xanthi FC from 29 September 2020 until 30 June 2022, which remuneration
during the overlapping period shall be deducted, leading to a mitigated compensation in
the amount of EUR 226,170 (i.e. EUR 250,000 – EUR 23,830).
Page 10 of 14
REF FPSD-102
40.
Subsequently, the Chamber turned its attention to art. 17 par. 1 lit. ii) of the Regulations,
according to which a player is entitled to an additional compensation of three monthly
salaries, subject to the early termination of the contract being due to overdue payables. In
case of egregious circumstances, the additional compensation may be increased up to a
maximum of six monthly salaries, whereby the overall compensation may never exceed the
rest value of the prematurely terminated contract.
41.
With the above in mind, the Chamber decided to award the Claimant additional
compensation corresponding to EUR 23,830, in accordance with the above-mentioned
provision.
42.
In continuation, the DRC took note of the Claimant’s request for EUR 20,000 as bonuses
being part of the compensation. In this respect, the Chamber highlighted that in accordance
with its well-established jurisprudence bonuses should be granted in case the player
effectively participated in the events triggering the relevant bonuses.
43.
As a result, the Chamber decided to reject the Claimant´s request for EUR 20,000.
44.
Consequently, on account of all the above-mentioned considerations, the Chamber decided
to partially accept the Claimant’s claim and that the Respondent must pay to the Claimant
the amount of EUR 92,000 and TRY 6,000 as outstanding remuneration plus interests and
EUR 250,000 as compensation for breach of contract, which is considered by the Chamber
to be a fair and reasonable amount.
iii.
Compliance with monetary decisions
45.
Finally, taking into account the consideration under number III.3.a above, the Chamber
referred to par. 1 and 2 of art. 24bis 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.
46.
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 and for the maximum
duration of three entire and consecutive registration periods.
47.
Therefore, bearing in mind the above, the DRC decided that, in the event that the
Respondent does not pay the amounts due to the Claimant within 45 days as from the
moment in which the Claimant, communicates the relevant bank details to the Respondent,
provided that the decision is final and binding, a ban from registering any new players,
either nationally or internationally, for the maximum duration of three entire and
consecutive registration periods shall become effective on the Respondent in accordance
with art. 24bis par. 2 and 4 of the Regulations.
Page 11 of 14
REF FPSD-102
48.
The DRC recalled that the above-mentioned bans will be lifted immediately and prior to its
complete serving upon payment of the due amounts, in accordance with art. 24bis par. 3
of the Regulations.
49.
Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
d. Costs
50.
The Chamber referred to article 18 par. 2 of the Procedural Rules, according to which “DRC
proceedings relating to disputes between clubs and players in relation to the maintenance
of contractual stability as well as international employment related disputes between a club
and a player are free of charge”. Accordingly, the Chamber decided that no procedural costs
were to be imposed on the parties.
IV. DECISION OF THE DISPUTE RESOLUTION CHAMBER
1.
The claim of the Claimant, Andreas Tatos, is partially accepted.
2.
The Respondent, Altay Sports Club, has to pay to the Claimant, the following amounts as
outstanding remuneration:
- EUR 15,000 plus 5% interest p.a. from 7 February 2020 until the date of effective payment;
- EUR 15,000 plus 5% interest p.a. from 7 March 2020 until the date of effective payment;
- EUR 15,000 plus 5% interest p.a. from 7 April 2020 until the date of effective payment;
- EUR 15,000 plus 5% interest p.a. from 7 May 2020 until the date of effective payment;
- EUR 3,000 plus 5% interest p.a. from 1 March 2020 until the date of effective payment;
- EUR 3,000 plus 5% interest p.a. from 1 April 2020 until the date of effective payment;
- EUR 3,000 plus 5% interest p.a. from 1 May 2020 until the date of effective payment;
- EUR 3,000 plus 5% interest p.a. from 1 June 2020 until the date of effective payment;
- EUR 10,000 plus 5% interest p.a. from 7 June 2020 until the date of effective payment;
- EUR 10,000 plus 5% interest p.a. from 7 July 2020 until the date of effective payment;
- Turkish Lira (TRY) 3,000 plus 5% interest p.a. from 1 July 2020 until the date of effective
payment and
- TRY 3,000 plus 5% interest p.a. from 1 August 2020 until the date of effective payment.
3.
The Respondent has to pay to the Claimant the amount of EUR 250,000 as compensation.
4.
Any further claims of the Claimant are rejected.
5.
The Claimant is directed to immediately and directly inform the Respondent of the relevant bank
account to which the Respondent must pay the due amount.
Page 12 of 14
REF FPSD-102
6.
The Respondent shall provide evidence of payment of the due amount in accordance with this
decision to [email protected], duly translated, if applicable, into one of the official FIFA
languages (English, French, German, Spanish).
7.
In the event that the amount due, plus interest as established above is not paid by the
Respondent within 45 days, as from the notification by the Claimant of the relevant bank
details to the Respondent, the following consequences shall arise:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid and for the maximum duration of three
entire and consecutive registration periods. The aforementioned ban mentioned will be
lifted immediately and prior to its complete serving, once the due amount is paid.
(cf. art. 24bis of the Regulations on the Status and Transfer of Players).
2. In the event that the payable amount as per in this decision is still not paid by the end of
the ban of three entire and consecutive registration periods, the present matter shall be
submitted, upon request, to the FIFA Disciplinary Committee.
8.
This decision is rendered without costs.
For the Dispute Resolution Chamber:
Emilio García Silvero
Chief Legal & Compliance Officer
Page 13 of 14
REF FPSD-102
NOTE RELATED TO THE APPEAL PROCEDURE:
According to article 58 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 20 of the Procedural Rules).
CONTACT INFORMATION:
Fédération Internationale de Football Association
FIFA-Strasse 20 P.O. Box 8044 Zurich Switzerland
www.fifa.com | legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
Page 14 of 14