The Proposed Reforms from Transparency International Unimplemented by FIFA

Below you can find the recommendations made by Transparency International in 2011in its report Safe Hands: Building Integrity and Transparency at FIFA which I have identified as having not been adopted by FIFA in its reform process. These of course comprise part of the reform evaluation wich I recent discussed at Play the Game and to which FIFA responded to here.

Overall, I identified 28 statements in the form of recommendations in the Safe Hands report. Of those 28, FIFA failed to even partially implement 23. Those 23 are listed below, to aid in discussion and (ideally) debate. Questions worth thinking about include: Which ones are most important? Which ones are secondary? Which may be off the mark? Comments welcomed either here or via email.

In coming posts I'll do the same with respect to the unimplemented recommendations from the pre-reform commissioned paper of Mark Pieth and those found in the first report of the FIFA IGC.

• FIFA should set up a committee of insiders and outsiders to review its code of ethics for the organization and its officials (be they elected or appointed, paid or unpaid) and employees.
• Clear conflict of interest policy with a transparent interests register for leaders (published, for example, on the FIFA website) 
• Disclosure of income of leading staff members as well as remuneration of members of the Executive Committee and other key bodies
• Guidelines for giving and receiving gifts at all levels of football governing bodies.
• Special guidelines for high-risk areas
• FIFA should establish a help desk to answer questions from anyone to whom the code applies about handling difficult situations (for example, how to deal with a specific invitation, or which gifts might be appropriate in a specific situation), providing anonymity if required.
• A maximum of two terms for positions including the Executive Committee and the Finance Committee
• Transparent and competitive elections and appointment processes
• Presence of non-executive (i.e. external) directors to the Executive Committee, Finance Committee and all major bodies
• The general secretary and the directors should be appointed for a set time-limit (for example five years with reappointment).
• We recommend that the multi-stakeholder group assesses the current standards
• Setting up a remuneration committee to decide on the remuneration packages, including bonuses, pensions, etc. of all senior FIFA officials. It should be guided by clear criteria, which should be decided by a larger decision-making body. Membership should include both internal FIFA and external (independent) representatives, the chair being one of the independent members. A report by the remuneration committee should be published in FIFA’s annual report. (These recommendations parallel good practice in the business world.)
• Publishing the audit reports from the local as well as from central independent auditors to give an account of the financial control system.
• Establishing an “Audit from below” i.e. publishing the use of funds in detail per confederation and member federation, so that interested parties can see whether the payments made match the services and/or goods/infrastructure received.
• [T]here is a need for additional transparency and more detailed public reporting. Public reporting cannot be limited to financial information; it must also disclose the criteria for, and processes behind, decisions made at the top.
• There should also be formalized and consistent reporting on anti-corruption activities integrated into already established reporting processes (e.g., accounting).
• FIFA needs clear published guidelines for the initiation and execution of investigations.
• Whistleblower protection rules and the appointment of an independent ombudsman Each suspicion has to be investigated professionally, by a body independent of the Executive Committee
• Each suspicion has to be investigated professionally, by a body independent of the Executive Committee
• Each breach of rules/code of ethics must have consequences. If a list of offences and sanctions is published, no board decisions will be seen as arbitrary.
• Any breach of criminal law must be referred to the appropriate authorities for prosecution
• FIFA, as well as its confederations and national federations using money allocated by FIFA, should report annually on anti-corruption policies and their implementation, as well as on any allegations and the actions taken.
• The organizing committees for all events under the direct control of FIFA, especially the FIFA World Cup but also FIFA Women’s and Youth tournaments, should be obliged to use Integrity Pacts4 (anticorruption contracts) for any construction projects and to publish reports under the new Sector Supplement Events of the Global Reporting Initiative, which provides guidelines for Corporate Social Responsibility.