Mapping the UK Landscape

1 The recommendations, structures and strategies proposed by this report are the views of the authors, and do not necessarily represent the views of UKAD.

Corresponding Author: Professor Mike McNamee School of Sport and Exercise Sciences Swansea University [email protected]

Professor Mike McNamee1,2 Gareth Parry1, Annamarie Phelps CBE1 1 School of Sport and Exercise Sciences, Swansea University, UK 2 Katholieke Universiteit Leuven, Belgium Integrity Report Foreword

While the power of sport to inspire people has organisations collaborate and share knowledge and not diminished, unfortunately it has become best practice if we wish to protect purity of sport. too common to hear stories of scandals, accusations and damning testimonies, where This meeting also revealed the multiple and the integrity of sport is called into question. potentially competing demands that integrity At UK Anti-Doping (UKAD) our remit is clearly units working in sport make of national governing focused on threats to sport caused by the use bodies (NGBs). It serves all our interests if we of performance enhancing drugs. However, in those institutions can work together to make if we failed to take account of other integrity those asks of sports as joined up as possible. issues in the sporting landscape, we could miss out on making the necessary links to This academic report is not intended to usurp understand the wider corruption in sport. organisations’ current systems of tracking integrity, but rather to serve as the foundation The integrity threats that face sport today are of knowledge and recommendations from which multifaceted and reach all areas, from on field future efforts may be built. It clearly demonstrates rule breaches to manipulations of governance the nature and extent of the consultation structures, from individual indiscretions to entire undertaken and contains an honest and systems of corruption. Recognising that integrity comprehensive collection of views and opinions issues take many forms, we must combat these collated by themes. threats by being robust and agile in our response. The first step in tackling these threats is to Within the sector we believe partners can unite understand the context in which they operate, to develop cohesive and efficient arrangements which is why UKAD commissioned Swansea for agreeing definitions, sharing information, and University to undertake this study into the current developing integrated education programmes. integrity issues within the UK, focusing particularly Whilst the report authors put forward on the issues that are consistent across a range of suggestions on structures and strategies this is sports. not necessarily the opinion of UKAD. Our focus is instead on the practical steps we can take with The motivation to undertake this project was born partners to protect sport from corruption. out of a meeting UKAD held in 2018 with a group of high-level stakeholders from across sport to discuss the nature, range and severity of threats to sport integrity and the reputation of UK-based sports. From this meeting one thing became clear; we can only adequately deal with sport integrity issues when we are united. No single organisation has the powers, capabilities or jurisdiction to meet the demands presented by these ever- Trevor Pearce CBE QPM changing integrity threats, so it is imperative that UKAD Chair

4 5 Contents

Executive Summary 8 - 13 Introduction 14 Sport Integrity: A Very Brief Review of Literature 15 - 26 • Some Useful International Benchmarks 28 -31

• Aim of this Research Project 32 Research Methods 32 - 33 • Ethical Considerations 34 Key Findings 36 • Online Survey 36 - 41

• Focus Group / Interview Data 42

• Sport Integrity Definition and Concept 43 - 46

• Drivers and Threats to Sport Integrity 47 - 49

• Current Approaches to Sport Integrity 50 - 53

• Organisational Structures and Partnerships for Sport Integrity 54 - 57

• Models of Delivery and Compliance of Sport Integrity 58 - 63

• Future Developments in Sport Integrity 64 - 71 Summary and Recommendations 72 - 74 Limitations 75 References and Appendices 76 - 80

6 7 Executive Summary

Integrity in Sport: Mapping the UK Landscape Prof MJ McNamee, GS Parry, A Phelps CBE

1. Good governance is now well-established as a vital part of running successful sports organisations. So too are policies and practices for selected ethical issues, such as anti-doping, equality and diversity, and safeguarding. Nevertheless, there is a lack of coherence and comprehensiveness concerning the approach to the broad range of threats to what is called “sport integrity”.

2. In November 2018, UK Anti-Doping (UKAD) convened a group of high-level sport stakeholders across the UK to discuss the nature, range and severity of threats to sport integrity and the reputation of UK-based sports.

3. Following the meeting UKAD commissioned a research project looking at integrity in sport, particularly the threats to integrity in sport and potential overlapping integrity issues and actors across providers. The aim of the current research is to map the landscape and to make recommendations as to the future, integrated, development of sport integrity in alignment with the good governance of sport within the UK.

4. The aim of the research is to survey the landscape of sport integrity in the UK. Its objectives are to describe and evaluate existing models and structures, to identify barriers and enablers and form recommendations for the development of sport integrity policy and practice in the UK.

8 9 5. The study comprised a multi-method approach Safeguarding/Welfare Officer; 6.4. Organisational Structures and to map the landscape of sport integrity in the Compliance Manager; Integrity Partnerships for Sport Integrity; UK. A questionnaire was sent, with agreement Manager; Anti-doping Manager; Well- from UKAD, to 81 sport stakeholders in being Officer; Discipline Manager; 6.5. Models of Delivery and Compliance of the UK. It secured a 63% response rate. In Integrity Investigations Manager; Sport Integrity; and addition, focus groups were conducted (n=2), Integrity Analyst; Head of Business in London and Manchester, to explore the Operations; Customer Complaints; 6.6. Future Developments in Sport Integrity. potential key issues, barriers and opportunities Clean Athletes Coordinator; for the development of the sport integrity 7. Highlights from these themes are as follows: agenda. Finally, the views of a range of high- 5.6. Respondents clearly identified the level operatives from organisations that are lack of resource, especially in small 7.1. Definition/conceptual clarity: key stakeholders (n=10) in sporting integrity organisations, to operate integrity despite the existence of a plethora in the UK were sought in order to probe in functions; of definitions, there was unanimous greater detail key issues arising in the previous support for a three-dimensional stages of the research. Key findings from the 5.7. Respondents identified a large range model of sport integrity. Although questionnaire were: of stakeholders that they worked each dimension could overlap, with in the integrity landscape. a model comprising personal 5.1. Stakeholders operated with multiple These ranged well beyond sport integrity, competition integrity, and definitions of sport integrity; 26 organisations. Examples included organisational integrity was thought to different elements were identified; Interpol, NSPCC, Social Services, capture the full range of issues falling UK Gambling Commission, and under the label of integrity. 5.2. 75% of the sample reported that their Universities. A third of the respondents organisation had an integrity function, were members of the Sport Betting 7.2. Drivers and threats: the fear of of which 79% reported to the Board or Integrity Forum; reputational damage and its CEO; consequences were uppermost in 5.8. In terms of misconduct reporting, respondents’ perceptions of the drivers 5.3. In terms of budget available to 85% of the sample provided either for sport integrity. A lack of resource, organisations, over half had a budget a whistleblowing or welfare support uncertainty around due processes of less than £10,000, with others over service. and procedures were identified as £2m, per year; key threats to the success of integrity 6. Key themes were developed from the functions. 5.4. Significant diversity was found in the questionnaire, which informed the latter roles (via job title) of those responsible qualitative phases of data collection. Focus for the integrity function. Nine distinct groups and interviews provided a forum for job titles were reported; more extensive discussion concerning:

5.5. It is acknowledged that sport integrity 6.1. Sport Integrity Definition and Concept; operations spread across a variety of topics, issues, and departments 6.2. Drivers and Threats to Sport Integrity; that reflect different approaches and structures for integrity work. 6.3. Current Approaches to Sport Integrity; The following roles were reported:

10 11 7.3. Current approaches: striking a balance 7.5. Delivery and compliance: both the criminal laws for event manipulation. between bottom-up education, nature of the sport stakeholder and The inclusion of independent elements and top-down compliance was its relation to financial resourcing to the development of a forum was characteristic of current approaches; influenced models of delivery and universally supported to counter financial resources played a critical compliance. Home Country Sport perceptions of conflicts of interest. role as did the size and commercial Councils and UK Sport did not Moreover, while leadership of such a orientation of the stakeholder. formally see themselves as regulators forum was discussed, there was a lack Better resourced organisations were of integrity issues, yet their capacity of majority on any one organisation. Of associated with a legalistic compliance to distribute financial resources, or those mentioned, the Department for model of integrity. This was informed withhold them, from “non-compliant” Digital, Culture, Media and Sport was by employment law as an unavoidable member bodies could not be ignored. the most widely cited. framework. Equally, other integrity Processes for enacting this power issues (safeguarding) were linked were not developed and could 8. 24 recommendations are listed in the report. to legal processes, while other appear to be ad hoc. Considerable Key among them are: cultural factors were not. In addition, support for the development of a acknowledging that much of sport is prioritisation framework was offered, 8.1. The formation of a UK-wide Sport supported by work that is volunteer- highlighting the need to identify Integrity Forum to develop and based, other models, including codes those elements of the integrity model share good practice and to lead and ethics committees, alternative that were the subject of legal and development of a national Sport dispute resolution methods were financial considerations. This might Integrity Plan; discussed as more appropriate produce a prioritisation strategy alternatives according to the issues at that acknowledges: issues subject to 8.2. The establishment of a UK-wide hand. legal obligations; ethical priorities so agreement on the operational important they could be mandated definition of Sport Integrity; 7.4. Structures and partnerships: several from those that would be merely models were described. Often aspirational. 8.3. The development of a UK-wide Sport elements which comprised integrity Integrity Education Strategy; (e.g. anti-doping; event manipulation) 7.6. Future developments: there was were carried out by a designated universal support for the development 8.4. The development of practice-sharing department or person, while other of a UK-wide Sport Integrity Forum. criteria and partnerships according to issues such as anti-discrimination It was acknowledged that the model the resource levels and shared integrity agendas (e.g. equality and diversity) of the Sports Betting Integrity Forum threats. were dispersed throughout the could be a good example but that organisation. Exploiting existing its brief was restricted to the betting partnerships between sports that had dimension of event manipulation, evolved in the successful roll out of its antecedents and solutions. Other mandated policies (e.g. anti-doping; suggestions included online support, safeguarding) could be utilised more portals for confidential information broadly. While knowledge sharing was sharing and the establishment of thought to be critical it is not clear that anything so definitive as “best practice” could be identified, though elements of “good practice” would be a more reasonable starting point.

12 13 Introduction Sport Integrity: A Very Brief Review of Literature

UKAD, the organisation responsible for promoting through this research; personal, competition, and The term “sport integrity” has gained global and Schneider, 1998) and sports organisational clean sport in the United Kingdom hosted in organisational. The dimensions are important to currency in recent years but there is still considerable structures, as well as the individuals involved. November 2018 a multi stakeholder meeting to distinguish analytically, even though they often confusion over what, in particular, it refers (Gardner Much of the literature on sports ethics has discuss the potential overlapping integrity issues overlap in real world contexts, since they locate et al, 2017; Harvey and McNamee, 2019). Certainly tended to adopt an issues-based focus, whether and actors across sport sectors. One outcome responsibilities in policy and practice that must there is a case for saying that many sport industry concerning anti-doping, abuse, harassment, was the commissioning of this independent be addressed for a holistic approach to the personnel reserve the term for discussions of “event sexual exploitation, simulation, and so on. Sports research, the aim of which was to map the sport phenomenon. It also recognises the different manipulation” (UNODC, 2016) while betting related journalists have, in addition, often focused on the integrity terrain and to make recommendations constituencies of sport, from administrator to manipulation has given rise to the term “sport failures of personal integrity of sports leaders, as to the future integrated development of sport athlete, coach to officials, whose words and betting integrity” and related policy development and, along with social and political scientists, integrity as a key element within the scope of actions must cohere if sport integrity is to be (see SBIF), while others have distinguished “narrow” investigated inept or corrupt structures. good governance in the UK sporting landscape. protected and promoted. and “broad” conceptions of sport integrity The study examined the views of key stakeholder (McNamee, 2013) to capture the distinction. While Each of these approaches has merit. To groups through online questionnaires (n=51), “narrow” refers to sports betting manipulation, understand when sporting competitions are face-to-face focus groups (n=2), and individual “broad” sport integrity refers to those ethical corrupted we must have a relatively clear idea interviews (n=10) to gain a deeper understanding practices that form our understanding of fair sport of what the “intrinsic goods and excellences” around approaches to sport integrity across the competition and conduct, which in turn form the (Simon, 1991; Devine, 2011) of sports are in order UK, the reasons for the development of integrity focus of this research. to understand when practices undermine them functions and barriers to, and enablers of, future (Lopez Frias and McNamee, 2018). The well- development. It is clear that understanding developments in known example of Rosie Ruiz, who took a shortcut sport integrity requires an appreciation for the to cross the finish line before any other competitor The central focus of the research, sport integrity, broader policy landscape out of which it emerges. in the 1980 Boston Marathon, is a classic case in is something of a moving target. It has only Increasing research attention has been given to point. She failed to run the complete 26mile/42 recently become a widespread term in sports particular, ethically salient issues over the last km course (using the subway mid-event!) and nomenclature. Unsurprisingly, then, there are two decades including, principally: anti-doping thereby failed to achieve the athletic excellences many competing definitions of sport integrity. (WADA, 2019); safeguarding (Brackenridge, 2002); of the endurance foot race. In essence her actions It is a contested concept. For the purposes of The central focus of the equality and diversity (Bray et al, 2013; Hayhurst, were no different to a cyclist riding with the this report we assert a definition that we believe 2011; Spracklen et al, 2006); event manipulation benefit of a concealed motor, who denies their is both inclusive and concise. Sport integrity research, sport integrity, and anti-corruption (Forrest and Simmonds, opponents the fair opportunity to contest the refers to the ethical value of sporting conduct is something of a moving 2003; Serby, 2015; UNODC); and the increasing athletic goal. and character, commitment to the authenticity adoption of models of good governance of sporting contests, and their coherence with target. It has only recently (Chappelet, 2013). In the last few decades, using the well publicised ethical codes of sport organisations, for those scandals in sport institutions such as those at engaged in sport in all roles and at all levels. become a widespread term While journalists and some scholars have the International Olympic Committee (IOC), This caters for the three overlapping dimensions in sports nomenclature. unhelpfully tended to lump together the vast the Fédération Internationale de Football of sport integrity, widely acknowledged in the portfolio of problematic practices in sport under Association (FIFA), and the National Collegiate academic literature, that were investigated in and the label “sport integrity”, sport ethicists have Athletics Association (NCAA), sport philosophers used the concept of “integrity” as a lens to have examined the concept of “integrity” not analyse negative practices in sport competition in relation to personal moral character or sport and practitioners. Unethical practices like those competition but to sport governing bodies listed above are thought to damage or corrupt and institutions (McNamee, 2013). Thus, the the integrity of sport by negatively affecting discussion on integrity has regained relevance in the interests of the sporting activities (Butcher sport ethics and sport politics as the result of the

14 15 interest in good governance in sport communities Baroness Grey-Thompson; Department for Digital, and procedures that must be followed but also and reported their findings publicly. One recent (Gardiner, Parry, and Robinson, 2017; Auweele, Culture, Media and Sport (DCMS) Sport Strategy; an element of individual and collective moral example of this is the Wood Report (2018) which Vanden and Parry, 2015; Geeraert, Alm and Groll, Code for Sports Governance – UK Sport/Sport reasoning for actions and behaviours in delivering was a full review into Australia’s Sports Integrity 2014; McNamee and Fleming, 2007). England; Tailored Review of UK Anti-Doping and implementing good governance, many Arrangements, which was heightened following (UKAD) – DCMS. of which are not very precisely circumscribed. the ball tampering scandal which hit Australian What these simple remarks reveal is made In relation to sports governance, McNamee Cricket in the Spring of 2018. more difficult by a plethora of definitions that It has typically been the case that these and Fleming (2007, p.428) take it “simply to have arisen in the sports ethics and governance developments have frequently been presented mean the structuring of an organisation so as Geeraert (2015a) collected data across 35 IFs literature. Often a lack of clarity and precision under the aspect of governance initiatives. The to achieve its aims or mission in ways that are scoring them on all 36 (under the four key has fostered conceptual inflation, to the extent phrase “good governance” has achieved global ethically defensible”. Similarly, Chaker (2004, elements listed above) indicators of the SGO, that sport integrity becomes a label for any and recognition in the world of sport largely, though p.5) writes of the “creation of effective sport- mainly through observing sources of information every ethical issue in sport. This is not helpful for not exclusively, because of the large-scale public related state agencies, sports non-governmental such as IF’s websites, statutes and regulations. policy makers nor researchers attempting to chart scandals of the Federation Internationale de organisations and processes, that operate jointly General Secretaries were also provided with an the field. There are simply too many maps and Football Association (FIFA), the International and independently under specific legislations, opportunity to review the data collected with models. For the sake of simplicity it may be easier Olympic Committee (IOC), the Russian state- policies and private regulations to promote a response rate of 43% (15 IFs). Despite being to identify there are three dimensions of integrity- sponsored doping saga, and more recently ethical, democratic, efficient and accountable subject to serious allegations of corruption related issues in sport, namely: organisational the high profile prosecution of Dr Larry Nassau sport activities”. The relationship between ethical (Schmidt and Borden, 2015; Pieth, 2011) FIFA integrity, personal integrity, and competition for his sexual abuse of hundreds of female standards and governance is an intimate one, was allocated the second highest score of all integrity (Archer, 2016; Cleret, McNamee and gymnasts in the USA. As a consequence most although ethical elements are often not explicitly IFs (see Figure 1: Geeraert, 2015a). This is a Page, 2015; Gardiner, Parry and Robinson, sports federations, national and international, delineated. worrying statistic bearing in mind the general 2017; Lopez Frias and McNamee, 2018). The appreciate the importance and relevance of good perception that FIFA was seen in many people’s interrelated dimensions allow us to articulate the governance (Brown and Caylor, 2009; Geeraert, There have been many definitions of governance eyes as corrupt and exhibiting poor governance, kind of integrity goal and failures that are the Scheerder and Bruyninck, 2012). This awareness offered as stated above, and also some, but whereas in reality, it was scoring higher than objective of any particular subject, whether it be has not, of course, resulted in all International not an extensive, level of research has gone other IFs, suggesting that there were serious event manipulation, doping, or corruption. Federations (IFs) or National Governing Bodies into developing practical indicators of good deficiencies in the governance across the board. (NGBs) exhibiting good governance. Many governance for sport (Geeraert, 2015) (Chappelet It is worth noting again, that good governance is What is clear is that the current landscape researchers attribute this, in part, to the lack of and Mrkonjic, 2013) (Chappelet, 2011). Geeraert not only about being in possession of, or having is dominated by organisational aspects and clarity in articulating the precise boundaries of (2015a) developed the Sports Governance developed a framework, but more importantly has been pursued under the aspect of sport “good governance,” creating a lacuna between Observer (SGO) as a practical benchmarking about how one delivers, implements and lives by governance. expectations and reality (Van Kersbergen and Van tool for IFs to enable them to monitor their said framework and set of rules. Waarden, 2004). governance against the four key elements of: There has been a rise of strategy documents Transparency; Democratic Process; Checks and One of the main findings of the study showed and resultant working groups that have emerged Recent research by Moore Stephens (2018) Balances; and Solidarity. that most IFs had internal audit committees and in this landscape. These include: Sport Betting stated that “sport governance” had many of the codes of ethics, but were weak in relation to Integrity Forum (SBIF); International Partnership usual features of governance elsewhere, but that There have been relatively few attempts to athlete representation and ethics committees. Against Corruption in Sport (IPACS); High there were additional features to consider such develop tools to monitor general ethical issues There were large individual variations across Performance Strategic Advisory Group (HPSAG)/ as match-fixing, anti-doping, safeguarding of within sports, perhaps due to sport largely being federations. Nevertheless, Geeraert stated that UK Governance Group; International Olympic vulnerable persons, and dealing with volunteer a rule-based activity. Possibly the only example most federations scored poorly on some key Committee (IOC); Council of Europe (COE); Wood directors. Sports governance therefore not is a report commissioned by Sport Scotland governance indicators, suggesting that there Report – Review of Australia’s Sports Integrity only includes regulatory procedures but also (McNamee and Fleming, 2005; 2009) of an is a more general governance challenge in Arrangements; Duty of Care in Sport Report – ethical ones, meaning that there are systems ethics audit of an entire sport organisation. It is international sport. perhaps surprising that so few organisations have conducted such an audit, or at least have done so

16 17 A significant element of Geeraert’s seminal survey (audit committee) and 1.97 (ethics committee) was the lack of established independent audit in the system, where a score of 1 represents ‘not and ethics committees with sufficient authority fulfilled at all’, 2 means ‘weak’, 3 is ‘moderate’, to execute important functions such as: efficient 4 is ‘good’ and 5 is ‘state of the art’, with financial controls, risk management, and proper FIFA being the only federation to score a 5. implementation/audit of ethics codes. Very Geeraert concludes by suggesting that one of few federations have robust and independent the biggest problems in this area is the lack of audit and ethics committees. Most federations authority provided to the ethical committees; score a 2, indicating that their audit and ethics this meaning they do not have the power to committees are not working independently and instigate investigations without the consent of the have very unclear or limited competences. On president or executive committee. average, the federations score a modest 2.09

SGO index

25% 35% 45% 55% 65% 0 FEI FIFA FIS BWF 5 ISAF FISA IIHF IAAF FIE 10 IHF UCI AIBA UIPM ITTF 15 WR FIG WA (FITA) WTF FINA Rank 20 FIBA FIH ICF UWW ISU 25 FIBT WCF IWF IBU FIVB 30 ITF IJF FIL ITU IGF 35 ISSF

Figure 1. Geeraert (2015a) Sports Governance Observer 2015 Index Scores showing to what degree the federations comply with the 36 indicators constituted in the four governance dimensions.

18 19 Audit committee Ethics committee

25 21 20 17

15 12

10 8

5 5 3 2 1 1 0 0 Score 1 Score 2 Score 3 Score 4 Score 5

Figure 2. Geeraert (2015a) showing whether organisations have internal audit and ethics committees (n=35) and how competent they are.

In response to the study some sports organisations, the rules of their IF and any national funding or including FIFA, conducted governance reviews legislative requirements. Whilst publicly funded and proposed further reforms (FIFA 2016), NGBs in the UK are now compelled to meet the and the The Association of Summer Olympic standards of the UK Code for Sports Governance, International Federations (ASOIF) introduced their they are equally influenced by their IFs which own governance benchmarking framework, ‘Key may have different standards, expectations and Governance Principles and Basic Indicators’ (ASOIF, accountability, and often very different levels of 2016), which is an externally verified self-assessment resource and rewards. With regard to term limits tool, but doesn’t assess relevance or adherence. for post holders, for example, the IFs have a much Again, as stated above, and of important relevance greater tolerance compared with the UK Code, is the integrity of individuals and organisations who putting UK NGBs at a potential disadvantage in would use such tools or benchmarking frameworks. influencing future decision-making. In contrast some These frameworks and assessments are only as IFs have better developed codes of ethics and good as the people or organisations implementing committees. However, UK NGBs and their funding them. partners, sponsors and investors have bona fide (commercial and reputational) interests in ensuring Although Geeraert’s study focuses on IFs, National that decisions relating to performance, elections, Federations or NGBs may be seen as being both procurement and, for example, attribution of events ahead of, or behind, the curve in terms of sports are carried out in a fair, transparent and ethically governance compared to International Bodies. sound manner. NGBs tread a fine line between compliance with

20 21 A limitation to Geeraert’s study is the lack ethically informed decisions. Organisations can of involvement of key stakeholders, with the have the best policies and structures, with a clear exception of General Secretaries, and this is very vision, mission and values, but having values surprising considering the frequency of the word printed on documents, and living those values “stakeholder” appearing in texts concerning are two completely different, though inter-related governance, and the author referring to the matters. A governance framework in itself cannot Principal-Agent Model (Jensen and Meckling, 1976) assure personal integrity although it can place as a powerful tool to examine relationships where effective checks and balances for integrity threats one stakeholder acts on behalf of another. or failures. It can also enable an organisation to demonstrate the tone and behaviours of a sport’s A complementary view of the importance of operations. assessing key stakeholder relationships can be found in Mitchell, Agle and Wood’s (1997) Sport Scotland, Sport Wales and Sport Northern “Stakeholder Typology”, which suggests that Ireland all launched their own Governance the dynamic of relationships varies according to Frameworks over recent years with specific the three key elements of power, legitimacy and reference to the Nolan Principles and behaviours urgency. Furthermore, the Financial Reporting expected of Board Directors, with Sport England Council (FRC) has very recently developed its latest and UK Sport following suit with the launch of the version of the UK Corporate Governance Code Code for Sports Governance in 2017. Since then, (FRC, 2018) with an added focus on relationships UK Sport has established a Sport Integrity Function between organisations and key stakeholders being to help re-build trust through visible changes in at the core of long-term sustainability and urging behaviour and culture following some very high- organisations to understand their stakeholders’ profile cases of athlete bullying (Roan, 2017). views. The framing of personal integrity is often captured These representations of organisational approaches in both negative and positive terms. Positively to the conduct of individuals and operations of expressed, integrity statements typically list a range sport organisations, by focusing on governance, of desirable values, though the process of their have had a tendency to skew, or at least focus selection and validity often goes un-noted. When narrowly, on organisational aspects of sport it is more specific it is usually in negative terms, integrity. Nevertheless, two key elements of good articulating misconduct and associated offences. UK governance relating closely to organisational Sport has developed a number of model policies integrity, that must be explored in greater detail, for misconduct and offers a template for UK-based are cultures and behaviours. Put in simple terms, sport organisations to develop their own integrity- both individuals and organisations must not only related aspirations and practices. “talk the talk”, but also “walk the walk”. One of the key initiatives of this function has been Good sports governance is not only about developing a “Culture Health Check” that collates structures, policies and procedures, but is also insights from all key stakeholders, including athletes heavily reliant on having a culture within an and staff, with the aim of creating positive cultures, organisation that allows it to thrive and make an early warning system highlighting potential

22 23 problems, and being a secure and anonymous to each other on the football pitch. The very clear referred to as “whitewash” activities, suggesting the formation, scope and role of the integrity way for individuals to seek support. What added threats of social media attacks and hacking that they are merely a means of covering up functions. The 8 steps are as follows: - these initiatives bring to life is the importance capabilities of groups such as the “Fancy Bears” scandalous behaviour and misleading people into of identifying key values and behaviours, and are added complications that must be taken into believing organisations or individuals are more 1. Create urgency – Develop a sense of urgency more importantly, living by and protecting them. account, as well as the problems of doping and upstanding than they otherwise might seem. across the whole organisation around the Identifying such issues is not a novel idea within match-fixing. Finally, Smith and Stewart (2010) Questions have been asked of people’s motives need for change, based on open and honest sports organisations, with such information usually suggest that some actions that are tolerated in when undertaking activities that could come dialogue about what is happening in the being contained or referred to within a code of sport would be enough to put employees of under the banner of “governance” such as FIFA’s sporting landscape. ethics. business companies in jail. This clearly suggests governance reforms (FIFA, 2016), which included that there are conventions or actions in sport, such changes to its ethics committee. Are such reforms 2. Form a powerful coalition – Convincing people Since first being introduced in the business as fighting in ice hockey, that are expected and genuine, or as suggested by Riordan (2007) mere that change is necessary through strong world as a tool for promoting ethical behaviour, tolerated, and these must be considered when attempts at ego-boosting or to cover up dubious leadership and support from key people in the indicating a company’s commitment to ethical evaluating code effectiveness. practices? In the current context, questions organisation. Having a coalition of influential business practices as well as to reprimand could be asked of all IF’s ethics committees, as people whose power comes from a variety of unethical behaviour (Singh, 2011), codes of ethics Therefore, the following questions arise: who is referred to in the research by Geeraert (2015a), sources. have become widespread instruments in sports tasked with developing the code of ethics within a as to whether their establishment and purpose organisations, but their effectiveness has been sports organisation?; what skills do these people is more a marketing ploy to provide members 3. Create a vision for change – Create a vision questioned (De Waegeneer, Van De Sompele and possess in order to do so?, and who makes and key stakeholders with a perception that they that links all the great ideas that are being Willem, 2016; McNamee, 1998). decisions related to sanctioning any violations of are taking proactive steps to improve ethical discussed around the potential change the code? Using the last example, we could ask behaviour within their organisation, or a genuine to create a vision that people can easily The different results on code effectiveness can rhetorically whether an individual working in a mechanism for improvement. It is also worth remember and understand. be attributed to the different methods used to major bank who punched a colleague from a rival noting that some ethics committees may be examine effectiveness. Kaptein and Schwartz bank during a business meeting ought be treated established with a genuine intention to improve 4. Communicate the vision – Ensure (2008) looked at the number of violations against differently to an ice hockey player punching an ethical behaviour but lack the necessary power to communication is frequent and powerful, a code, but this method would not capture those opponent? implement. and embedded within the organisation. individuals with a fear of disclosing due to an Keep it fresh and part of the organisation’s inappropriate or lacking whistleblowing policy. As highlighted above by Geeraert (2015a), many Considering the possibility of successful day-to-day operations and “walk the talk” Another complicating factor in this discussion IFs have established ethics committees, and governance reforms, Katwala (2000) presented by demonstrating with actions and not only is the uniqueness of sport in comparison to these vary according to their scope and power. three possible scenarios: organisational change words. traditional businesses. Babiak and Wolfe (2009) Due to the lack of available literature on the from within, external pressure, and most likely suggested that the sport sector has its own topic of ethics committees in IFs it is difficult to a forced change as a result of crisis. The key 5. Empower action – Provide key individuals and set of characteristics that could influence the ascertain their effectiveness and whether they challenge that remains is for sports organisations teams with the knowledge and resources to effectiveness of ethical codes. One of the most meet the required standards of good governance, to achieve fundamental rather than superficial deliver the change and remove any obstacles prominent is the amount of scrutiny presented especially in relation to democratic processes, change through the establishment of integrity or barriers that may present themselves. by high media visibility in comparison with other separation of power, terms of office, and skills- functions. sectors. based appointments. 6. Create quick wins – Using success to motivate According to Kotter (1995), whose work on organisations can be achieved through A clear example of behaviour changes over Another reason for looking at the scope and change management is highly cited and identifying easy and short-term wins. These the past few years can be seen in professional function of ethics committees is related to respected, managing fundamental change targets should be achievable and with little football, where footballers are regularly seen with scepticism about their purpose. There have been within organisations requires following an room for failure. their hands covering their mouths when speaking numerous reports of governance initiatives being 8-step process, one that can also be applied to

24 25 7. Build on the change – It is important not to declare victory too early, and short-term wins should be built upon to achieve long-term change. Even some failures can be reviewed to improve future performance.

8. Make change stick – Change should become embedded as a core element within the organisation, and more importantly within its culture. Continuous effort should be made to ensure that the change is seen in every aspect of the organisation and driven by key leaders.

Reviewing current practices of ethics committees across some international sports federations indicates differences in approach and purpose.

Create a vision for change – Create a vision that links all the great ideas that are being discussed around the potential change to create a vision that people can easily remember and understand.

26 27 Some Useful International Benchmarks

What are International Federations doing with transparency expected by the world’s athletes and more democracy in voting processes, and each respect to Ethics and Integrity structure and supporters. The Board has a critical governance member of the Council must be subjected to functions? role rather than a management function, similar in a fit and proper person check. A maximum of style to that of a corporate board. It is responsible three terms of four years has been introduced Responses to the need for integrity development for approving and reviewing strategy, policies and all remuneration will be disclosed each by IFs are, unsurprisingly, varied. The International and plans for the Unit and for appointing and year. Another key change in FIFA has been the Association of Athletic Federations (IAAF) recently monitoring the performance of the Unit’s Head separation of powers (board versus business established an Ethics Board which was set up who is in charge of its day-to-day operations. operations) in order to reduce conflict of interest as an independent judicial body in accordance and mirror best practice. The FIFA Council’s new with its articles. Its main aim is to safeguard the The International Tennis Federation (ITF) has role will be supervisory and strategic and will authenticity and integrity of athletics and take an Integrity and Development Department be supported by a fully Independent Audit and all possible measures to mitigate and eliminate that focuses on the development of tennis Compliance Committee which will monitor the corruption and harm from the sport. An important worldwide, anti-corruption, anti-doping, science whole structure. In his recent follow-up report, note is that members of the Board could not be and medicine, and technical elements of the Geeraert (2018) found that FIFA continued to current members of the IAAF and could only be game. It is also responsible for coaching, the score higher than other IFs when compared across appointed for two terms of four years each. Grand Slam Development Fund, rules of tennis, 309 good governance indicators, with one of its ITF Constitution and good governance. The ITF key strengths in relation to internal accountability Within the Board’s powers is the authority to is also one of seven key stakeholders alongside being related to the establishment of its ethics appoint independent investigations, issue fines, the Association of Tennis Professionals, Women’s and audit committees and the adoption of a code or suspend people. But, since 3 April 2017, the Tennis Association, and the four Major Tennis of ethics. Its independent ethics committee is Athletics Integrity Unit has assumed jurisdiction Tournaments which fund the Tennis Integrity Unit appointed by the general assembly and has the to deal with any new complaints or matters (TIU), an operationally independent organisation power and authority to investigate violations of its concerning integrity and ethics within athletics, based in London. The TIU’s main function is own accord. regardless when the matters complained of to prevent corruption, investigate threats and or referred to occurred (unless the matter was educate all players through a compulsory Tennis The International Olympic Committee’s IOC Ethics already before the IAAF Ethics Board as at 31 Integrity Protection Programme (TIPP). The TIU Commission has some major accomplishments December 2016). The Athletics Integrity Unit was established in 2008 and, following a recent to its name including reforming the IOC Olympic operates independently from the IAAF and has independent review in 2016, has more than Charter, the Code of Ethics (IOC, 2016), and complete authority for the management of ethics doubled the number of full-time staff to 17, establishing an ethics and compliance office, but and integrity in athletics in accordance with the including a dedicated three-person Education and has also faced criticism for a lack of independence applicable rules. Training Division. in relation to member composition, lack of transparency of reports produced for the IOC The Athletics Integrity Unit represents a new era Following significant reforms in 2016 FIFA’s (FIFA, Executive Committee, and having a lack of in the management of threats to the integrity 2016) aim was to become a modern, trusted, decision making power, issuing opinions that are of sport. Through the formation of the Athletics professional organisation. It is aware that it will advisory but not binding. Integrity Unit, athletics has become the first sport take time to change the culture within the world internationally to delegate complete authority for of football but has committed to excel when it As part of its Olympic Agenda 2020 (IOC, the management of its integrity programmes to an comes to governance. Its Executive Committee 2014), and to comply with the Basic Universal independent body. Fully separated from the IAAF, has been replaced by the new FIFA Council Principles of Good Governance of the and reporting through its own Board, the Athletics where the President has less power and plays Olympic Sports Movement (IOC, 2008), the Integrity Unit operates with the level of rigour and more of an ambassadorial role, there is much IOC included a recommendation for its Ethics

28 29 Commission to become more independent. conducting an extensive governance review for Following the proposed changes, members of the first time since 2004 with the aim of improving the ethics commission will be elected by the its position as a world-leading sports organisation. IOC Session (member associations) and not The review includes looking into the structure, role by the IOC Executive Board (which included and function of their Legal and Ethics Committee the IOC President). Although the IOC should which offers advice to the Governing Board be congratulated on its recommendation to on issues including membership confirmation improve the independence of the commission, its and ethical principles. The Committee also has meaning of independence must be questioned responsibility for the IPC Code of Ethics and as its function is to investigate and propose includes a set of legal obligations and seeks sanctions to the IOC Executive Board, through to describe boundaries of acceptable human the hands of the President, who holds the power behaviour and strives to encourage ethical to implement or not, with recommendations behaviour through advice and education. The remaining confidential until a decision is made findings of the review were presented at the by the Executive Board. The Commission has IPC’s General Assembly in October 2019 and are two key functions: continuously updating the subject to a 12-month consultation process. ethical principles as well as implementing provisions based on the values and principles It is worthwhile noting that ethics and integrity- of the Olympic Charter; and conducting related sports structures will develop according investigations into breaches of ethics submitted to the needs and nature of the particular host to it, and as mentioned, subsequently making organisation. Although the principles of integrity recommendations for sanctions to the IOC remain the same, different organisations will Executive Board. The role that the IOC Ethics apply them differently and should not directly be Commission plays is heightened by the fact that compared without due caution. National Olympic Committees, International Federations, Recognised Organisations and the Organising Committees for the Olympic Games undertake to adopt, for their internal activities, a code of ethics based on the principles and rules of the IOC Code of Ethics, or for some, actually adopt the IOC Code of Ethics.

A recent governance review of the IOC conducted by Institute for Management Development (IMD, 2017) included recommendations to regularly update members on the code of ethics, improve the independence of the Ethics Commission by having an independent secretary, and delegate sanctioning of breaches of the code of ethics to a third party, and for it not to remain a function of the IOC’s Executive Board. The International Paralympic Committee (IPC) is currently

30 31 Aim of this Research Project Research Methods

The aim of this research is to map the terrain and The UK sporting landscape is very diverse with international sports federations and other make recommendations as to the future, integrated different cultures, historical influences and non-sport related bodies. Confidentiality and development of sport integrity as a key element resource available to organisations. A mixed anonymity measures mean that it is inappropriate within the scope of good governance of sport methods quantitative/qualitative approach to report further detail concerning the within the UK. allowed the researchers to capture and interviewees. understand these differences. Additionally, the Objectives: integrity functions must consider the views of all A semi-structured format using a topic guide (see stakeholders and largely depend on individual or Appendix 1) developed from the literature review 1. Provide insight into the extant approaches collective behaviours. Social interactions within and online questionnaire responses was used to to sport integrity, understood in its broadest the human community cannot be fully captured by explore people’s feelings and experiences of sport sense as they currently stand. survey data (Chappelet and Mrkonjic, 2013). integrity functions. All focus group and interview participants were asked to read an information sheet 2. Provide insight into the reasons for the In order to capture the views of all key and sign an “informed consent” form to participate development of the sport integrity agenda, and stakeholders, the researchers undertook the in the study and were encouraged to talk about their barriers to that development as they might be. following: experiences including intrapersonal, interpersonal and environmental factors. 3. Provide recommendations for the synergystic 1. Mapping exercise undertaken via an development of the sport integrity agenda online questionnaire that described extant 12 participants took part in the focus groups with as well as sharing policies and emerging best approaches to sport integrity, understood in its a further 10 individuals being interviewed. Each practice. broadest sense. focus group/interview lasted between 30 and 120 minutes. They were conducted by the researchers 2. Analysis of the questionnaire led to two in July/August 2019 either at a safe, private stakeholder focus groups (one North UK, location, making every effort possible to minimise one South UK) to tease out reasons for the the exposure of participants in the research study development of the sport integrity agenda, to others, or via skype/phone. All focus group and barriers to that development. and interview data were transcribed verbatim and independently read by both the researchers. Key 3. Insights gained from both phases led to quotations were independently identified and the identification of key individuals and grouped in categories, themes and sub-themes, NGBs (n=10) who were invited for in depth to achieve “consensus validation” and to reduce interviews to probe in greater detail these the potential bias among or between the research issues and to elicit recommendations for policy team, before resolving any disagreements and development. agreeing on the final cluster of categories.

The online questionnaire was shared via Survey Monkey and consisted of 35 questions. 51/81 stakeholders completed the questionnaire giving a response rate of 63%. The sample respondents were from a range of key stakeholders including UK sports councils, national and British governing bodies of sport, law enforcement, government,

32 33 Ethical Considerations

Ethical approval for the study was granted by Swansea University (reference 2019-037). Importantly, all participants were notified of the processes to secure confidentiality and anonymity in the information sheet and the informed consent process, but, as the sample was taken from a selective group, it would be impossible to guarantee absolute confidentiality and anonymity. Therefore, in order to protect individual participants as much as possible the following safeguards were put in place.

The identities of the sample were not revealed to any other participant other than those participating in focus groups who were participating under Chatham House rules. Each focus group and interview participant were coded with a letter and a number, and general labels such as “NGB”, “sports council”, and “law enforcement” used. Transcribing of all interview data was done by a member of the research team and will under no circumstances be shared or discussed with anyone outside of the team, except anonymously. The data was transferred to a secure laptop protected device immediately after each interview.

34 35 Key Findings

Online Survey Definition of Sport Integrity Interestingly, two respondents stated that sport Organisations with Integrity Functions 51 out of a possible 81 stakeholders who were When asked to define the term sport integrity in integrity did not include safeguarding, equality 38 respondents (75%) stated they had a sent the questionnaire via an email from UKAD’s their own words, numerous different definitions and diversity. This heterogeneity reflects the recognisable integrity function(s) within their offices responded to the survey giving a response were received. As mentioned in the literature literature and policy landscape internationally. organisations, and the majority of these functions rate of 63%, which is extremely high and confirms review it seems that there is no one definition had ultimate oversight by the Board (19) or Chief the importance of the sport integrity agenda to of sport integrity being used across the UK thus It was important for the research team to Executive Officers (CEO) (11). the stakeholders. making it difficult when trying to compare and understand the variety of respondents’ views asking people to respond on the topic. Below is a and perceptions of sport integrity. Due to the Sport Integrity Budgets There were 35 questions included in the survey list of areas included in the definitions beginning huge disparity of responses, responses to the Again, there was huge disparity in the annual (see Appendix 2). Respondents were free to with the most referenced. questionnaire can only be taken as individual resource available to organisations, with over half answer as they saw fit, for example, depending responses based on the respondents’ own being less than £10,000, and others over £2m. 11 on an answer to question 3 (yes/no) respondents organisations or individual perceptions of integrity respondents were unable to answer this question would automatically move to either question 4 or definition, functions, scope and powers, and as integrity was dispersed across different question 23. not as a collective discussing exactly the same departments and different budgets across their phenomenon. Nevertheless, it is fair to say organisation. Definition of Sport Integrity that most respondents were working within a 30 reasonably close set of parameters to each other Job Titles and Experience of Lead with some seeing integrity with a narrow focus, Integrity Officers 25 and others with a quite broad focus. When asked to list the job title of the person heading up the integrity function of the 20 Further information gathered from the online organisation the following variances were found. survey provided useful information for developing Listed in order of popularity (top to bottom, left to 15 the key topic areas to discuss in further detail right). during the focus groups and interviews. 10

5

0 Head/Director of Integrity Head of Operations and Governance Trust Ethics Safety Bullying Equality Honesty

Diversity Head of Legal and Compliance Cheating Selection Inclusivity Disciplinary

Match-fixing Anti-doping and Integrity Officer Transparency Safeguarding Whistleblowing Data protection Anti-Corruption Performance Manager Gambling/Betting Good governance Child Protection Officer Doping/enhancements Anti-doping Officer Fair play, level playing field Fair play, Technical Executive Outside influence/Manipulation Behaviour/Cultural Environment Protect values and ethos of sport Protect Doing right thing in the right way Head of Governance Rules and Regulations to protect the game Rules and Regulations to protect

Figure 3. Key areas identified when considering the definition of sport integrity Figure 4. Job Titles and Experience of Lead Integrity Officers

36 37 The majority of these roles listed above are In addition, 77% either have a Master’s (36%) or accountable to the Board, CEO or Director of Legal degree (41%), and over half of them lead teams/ and Governance. The range of legal/non-legal units with four or more staff. 17% work alone with direction is something that will be picked up later. no other colleagues working within an integrity function. It appears that integrity functions are reflected in personnel of a considerable degree of experience Sport Integrity Staff and/or seniority. 80% of the roles are full-time In addition to those heading up integrity units, the positions and with occupants either being in post following job titles were shared for those working for over 10 years and very experienced or have within integrity teams, again listed in order of been in post for under two years. This may be a popularity (top to bottom, left to right). result of the recent increase in integrity related roles across sport. Many of the postholders have a background in management (35%) and law (30%), with others coming from police (15%) or safeguarding (15%).

Safeguarding/Welfare Officer Integrity Investigations Manager

Compliance Manager Integrity Analyst

Integrity Manager Head of Business Operations

Anti-doping Manager Customer Complaints

Well-being Officer Clean Athletes Coordinator

Discipline Manager

Figure 5. Sport Integrity Staff Roles

38 39 Post-holders again came from a variety of Barriers to Sport Integrity Reporting Mechanisms backgrounds with the majority having experience Outside those organisations currently with The term “whistleblowing” is the most commonly as safeguarding officers, police, social workers, established integrity functions not many were used label for processes of reporting misconduct. sports development, coaching and regulatory/law. looking at creating or establishing integrity Even then the literature distinguishes “internal” 85% of these roles were full-time positions with functions. Some referred to the fact that integrity and “external” whistleblowing according to 78% of post-holders holding either a degree or was seen as part of governance and was spread whether the report uses an organisation’s Master’s degree. across many different functions as a reason not to own system, or whether the whistleblower or establish a specific integrity function. Others listed complainant goes to an external agency or the following barriers. organisation to report their concerns. Moreover, internal systems are normally recommended as the default, and that external whistleblowing (e.g. to media) should only arise after internal mechanisms or procedures have been attempted or exhausted. In addition, these systems may Lack of resource Bringing all integrity issues under require the whistleblower or complainant to one umbrella identify themselves or enable anonymised Organisation too small reporting. Of course, for this to happen the Education done in a seperate organisation must have a publicised process. Change of staff function

85% of respondents provided either a Serial complainers Sports development and core whistleblowing or welfare support service to business function prioritised their members. The success or uptake of these initiatives is unknown. This would be an important item to be addressed in any ethics audit.

The data above does not provide sufficient Figure 6. Barriers to Sport Integrity detailed evidence to make any specific claims for the development of sport integrity across the UK. Its purpose is principally descriptive: in capturing this baseline data the research team could describe the existing sport integrity terrain in the UK, and was able to take an informed view of key areas to be probed in the next stages of the research. The findings above, combined with the recent literature review, allowed the team to identify key stakeholders in the UK and invite them to participate in more detailed discussions on sport integrity in the UK via interviews and focus groups. It also allowed the team to develop a clear topic guide of areas to explore during the focus group and interview discussions.

40 41 Focus Groups and Interview Findings and Discussion Sport Integrity Definition and Concept

After conducting and transcribing the interviews, discussed in the order presented therein. Where It came as no surprise that the most basic lack of environment for good citizens to live in, that gives the first two lead authors (McNamee, Parry) the data emerges from a Focus Group (i.e. FG1; clarity in relation to sport integrity was evidenced you the basis or the breadth really of integrity. The independently reviewed the transcripts to FG2) it will be indicated by FG, and where from an in both focus groups and interviews. It would be list is pretty extensive. Some more sport specific identify key concepts (codes) and sub themes interview it will be indicated by a Participant and unreasonable to expect clarity in operation where stuff, we are talking safeguarding, equality, (memes). In reviewing the data, 240 quotes were number (e.g. P5). the research literature is itself a contested terrain. culture.” (P4) selected then grouped into the six key themes. Without clear conceptualisation, comparisons Several sub themes were identified within those between policy and provision are made These quotations are indicative of heterogenous themes. These are listed below in Table 1 and are problematic. views of sport integrity but reveal the basic confusion surrounding the conceptual boundaries A key challenge then in simply charting the (criteria) of the term. Often, interviewees or focus UK landscape is to compare different, albeit group attendees were more comfortable talking overlapping, maps without having a consistent about particular elements of sport integrity. A working definition of sport integrity. The following problem arises then, in whether sport integrity 1. Sport Integrity Definition and Concept comments highlight a plethora of views and some is a separate, specifiable entity or whether it is Clarity; Coherence; Resource; Three-Dimensional Model of the challenges faced in summarising sport merely the sum of particular parts (anti-corruption, integrity and making it applicable to a wide range anti-doping, safeguarding, etc). The problem can 2. Drivers and Threats to Sport Integrity of stakeholders. be captured by a fruit and vegetable analogy: is Reputation; Reactive – Preventative Approach; Lack of Resource; Processes sport integrity like a peach, with a core, or like an and Procedures; External Threats “I think sports integrity is hard, it means different artichoke comprised only of its leaves and with things to different people. Half of the art is being no core? Even if it were the latter, however, there 3. Current Approaches to Sport Integrity able to articulate something” (FG1) would still be a need to achieve a consensus Education/Compliance; Risk; Working Together; Tools for Compliance; over what those constituent parts ought to be. Rules-based vs Values-based; Transparency “we’ve talked about a whole range of things There is no sense in which a universal standard here and this is one of the things, we’ve kind exists before this research. To the contrary, and 4. Organisational Structures and Partnerships for Sport Integrity of classified integrity as meaning safeguarding, bearing in mind that the UK is a leading sport Dispersed Model: Effective Leadership and Communication; International gambling, anti-doping” (FG1) nation taking ethical issues more seriously than Relations; Partnerships many, perhaps most, others, it is up to leading “The way we would describe integrity is anything nations, and/or IFs (e.g. IAAF, FIFA) and/or event 5. Models of Delivery and Compliance of Sport Integrity from upholding the core values, sportsmanship organisers (e.g. IOC, CG) to determine the Financial Pressure to Comply; Resource; Principle-based Approach; Tiered [sic], teamwork, gamesmanship [sic], but also to boundaries and elements of the concept of sport Approach; Mandatory vs Non-mandatory include safeguarding, anti-doping, gambling, anti- integrity. corruption measures and agent’s integrity, and 6. Future Developments in Sport Integrity through to financial integrity as well” (P8) The conceptual problem is not simply an Sharing Best Practice/Information; Education; Continual Professional academic matter. It is both philosophical and Development on Culture/Behaviour; Creation of UK Sport Integrity Forum More generally another stated: practical at the same time. It has direct economic, legal, political and operational ramifications. This “it’s things like, I’ve already said fair play, fair is revealed in organisational structures, scope, and competition, standardised practices, honesty, powers. The following quotations are indicative: team spirit, not such a good one but the values placed on camaraderie, character building, “so, in our sports strategy we’ve got a section Table 1. Themes and Sub themes good citizenship, so I suppose if you define what which is titled “The Integrity of Sport” which then a good citizen is, and therefore what a good breaks it down into anti-doping, manipulation of

42 43 sports competition, and fighting corruption and Finally, the point that sport integrity, whatever it breaches within integrity, but our breaches are “I quite like the simplicity of that” (FG1) then goes on to governance. So that doesn’t is finally taken to mean, should not be seen as a completely different. So their clubs are allowed to incorporate safeguarding and duty of care under problem only for elite sports was mentioned by do stuff our clubs wouldn’t be able to do and our “I think that for me that [three areas of integrity] the same.” (P5) two very different stakeholder interviewees: intermediaries are allowed to do things they’re works quite well because, I came into this meeting not.” (FG1) thinking where does this start and where does this Aside from issues of coherence, one participant “I think sports integrity is a phrase that’s used finish, and I think at a very early stage, that clearly spoke of some integrity issues being “big quite a lot with high performance, elite sport, but In contrast, a further and very significant you are, I think this absolutely [is] something [that] enough” to have a distinct function: it doesn’t mean that it doesn’t exist elsewhere, it’s explanation between heterogeneity of approaches could be written up around it, and I would like to just managed in a different way. It’s more the risks to sport integrity was based on perceptions think most people would buy into” (FG2) “The main things in terms of integrity we would of things, bad things happening” (FG2) of available resource and prioritisation. In all say are anti-corruption, anti-doping which is one interviews the issue of resource was addressed. “So I kind of see this as, as long as this is backed of my main areas, good governance and it’s kind Whereas we should be wary of the It was universally acknowledged that disparate up by the idiots guide or Sports Integrity 101 then of a grey area as to whether or not safeguarding, approaches were justified by the limiting factor of there is a way that you can make it work” (FG2) welfare, duty of care that kind of area falls under “role the media plays also creates the link resources available to the relevant organisations. it as well. We’ve actually got a separate team that between sports integrity and high-performance “Tanni Grey’s report [Duty of Care In Sport Report] deals with that side of things, but, there’s obvious sport. You’ve also had in football historic things “my advice to other sports, smaller sports with covered so many different things but, in the end, ways that would fall under integrity as well, so it’s about safeguarding issues, so I don’t know less resources is to look at integrity in the round they broke down into seven areas or principles. not strictly treated as integrity issues, they’re seen whether other people would capture that in and to consider what is integrity, because it is I think when you do that, people find it easier to as big enough issues that they’re stand-alone integrity, but I think that participants at grassroots broad. In my view sports ethics and integrity are know where they fit and what they can influence but they can come under the integrity umbrella, level you might easily say a sport’s got a lack of more than just sports betting which might not be and maybe play a part with, so it’s as good a but really for us its mostly anti-corruption, match- integrity if it’s not able to protect its participants high priority to many of the smaller sports at all, model as I think, yeah” (P4) fixing, anti-doping and good governance.” (FG1) or people” (P3) but safeguarding, doping and probably should be higher priority because of player welfare, athlete “and obviously we’ve now set up policies, we Even then, it was a moot point how sport integrity Not every participant agreed that heterogeneity welfare” (FG1) ensure governing bodies have illegal betting and cohered with existing structures and policies: was a good thing. The following quotation reveals anti-bribery policies as well. So that would also diversity among well resourced professional This broader concept of sport integrity was sit underneath integrity. A broader definition for “My immediate reaction here is I think integrity sports; supported across the selected stakeholders. me now, as it now sits under culture, integrity and is a word that should sit above governance. I Interviewees were presented with the three- welfare is probably along the lines of three areas. think integrity in my definition is very much a “even similar sports can’t agree sanctions in the dimensional model of sport integrity highlighted One is personal integrity, second is organisational strategic word and it has to have a dotted line to same way because the sports run in different ways, in the literature review above (personal; integrity, and the third is what I would call Global governance. But I think there’s a danger in putting and that’s just in sports betting, before you get competition; organisational). Respondents Sporting Integrity” (P7) it too close to governance, because the danger into intermediaries, financial misconduct, inclusivity were unequivocal in their support for it. One here is everyone thinks integrity is governance. all those different areas, because sports are so respondent, below, reported that an existing Integrity is more than governance. You and I know fundamentally different so I think what you’re Culture, Integrity and Welfare Group is already there are many organisations and individuals who saying about a code I think you would have to be using a similar terminology but extended its demonstrate and abide by good governance very careful in how that would work in order for it scope to an international landscape. The support because they have to. But that doesn’t necessarily to be actually workable for every sport because is captured in the quotations below: mean they are abiding by the rules of integrity” they are so different in the integrity space, just (P7) around this table and we’re a tiny fraction of the “I’m more comfortable with that kind of sports. Look how different we all interpret integrity classification than just saying it’s safeguarding, and even within sports who have similar integrity, gambling, anti-doping, because I kind of, for me our sports are similar, we are big team sports, we at the moment there is an integrity challenge to both include financial misconduct or intermediary what is sport” (FG2)

44 45 Drivers and Threats to Sport Integrity

From this a model can be proposed, consistent and vulnerable people, but it also comes under As a way of understanding the genesis of “So I think that’s a really hard question to answer with the stakeholder perceptions and adding an organisation’s responsibility in ensuring there extant sport integrity developments, we probed what the driver is, I think most sports or certainly some detail to operationalise the three are clear safeguarding policies and procedures in interviewees about the drivers for sport integrity. ours has always been concerned about having a dimensions. place, and that these are clearly communicated to What kinds of issues or incidents had made their fair game whether that be fair in having financial all members. Equally, bribery is an interpersonal organisation develop policies and practices to regulation provision or fair and having inclusivity Figure 7 is a depiction of what the three-level transaction, a form of personal misconduct, but combat integrity threats? It was clear that integrity and standing up against any discrimination model of integrity could look like. All three it can drive sports betting manipulation, and functions were developed through a more reactive through to fair as in making sure that what people dimensions of integrity overlap and thus are not it needs organisational responses. This kind of approach often concerned with limiting reputational are seeing on the pitch is a fair game, whether mutually exclusive. For example, safeguarding can approach to articulating sport integrity is likely damage. In some cases, this had led to more that be because people are not doping or not be a personal issue with each individual involved to allow actors and organisations to approach proactive discussions and developments with some betting and match fixing” (FG1) in sports playing a role in protecting children integrity issues ‘in the round’ so to speak. focused around protecting the “fair game”. Thus: “So, there’s an element of us wanting to keep a lid “those issues come from the misconduct space on it for reputational reasons obviously” (FG2) and understanding why they were happening and what mechanisms we can put in place to prevent The threats to sport integrity thus vary according SPORT INTEGRITY them or how best to manage them. It was a to the sport, the challenges it presents, the reaction to issues that were going on and now it’s prevalence of the issue and whether it is related trying to be preventative in nature and educating to criminal laws (cf safeguarding v sport betting Personal Integrity: Organisational Integrity: sports.” (FG2) manipulations), and of course proper self interest • Individual behaviour • Collective behaviour by way of reputation management and its potential • Individual values Personal Organisational • Systemic action “Yeah, from our perspective there’s always a financial implications, which is possibly the only • Moral compass • Culture driver, for us in terms of integrity and in the driver likely to be shared by all organisations, albeit • Safeguarding • Good governance • Personal • Organisational values context of your question there are different issues to differing degrees. responsibility • Collective decision that rise under that heading, for us it was child • Do the right thing making (Board) safeguarding in the mid 90’s, so integrity in that By way of anticipating future developments we • Sportmanship Competition • Environment form was our driver” (FG1) asked respondents what they believed the biggest • Player Agents • Equality and Diversity threats to sport’s integrity were and would be in the • Discrimination • Financial Integrity “integrity matters that fall within my remit and future from their respective organisations and those • Education/Support our legal and governance remit its 10-12-15 they worked with. The sum of responses was again things. The answer to the question in terms of quite varied depending on the structure and type Competition Integrity: what drives each of the initiatives in all of those of sport stakeholder, yet the key organisational • Rules of the sport integrity issues the answer is going to be totally threat to most seemed to be lack of resource for • Competition different for all of those so, we are … have sports integrity related developments and functions. structure • Fair competition betting side of things and I’d say the driver in that • Anti-doping area is seeing what other sports who are more “If you say to anybody in a governing body outside • Match-fixing advanced than us… and just being round these of the compliance team that we’re going to take • Bribery/Corruption tables with the likes of ***** and listening to what money out of performance, so we can get a lawyer they’re doing and us going away and thinking we on board, then nobody else is going to vote in should do something more preventative because favour of that at all, until something goes wrong and Figure 7. A tripartite model of Sport Integrity we know ***** is quite, it’s not hugely bet on that’s the thing, when you said “why have you done compared to other sports in England so that that” I mean I can say this is the reason they’ve done would be more of a preventative approach. But it, but there has been stuff out in the press about then safeguarding [is] obviously the driver and [is] us and I imagined it would have been the driver of very much driven by legislation” (FG1) that, that needs to be sorted before it happens and

46 47 I don’t think you can say. I don’t think sport should it wrong, or a financial cost that you have to take to manipulate the data feeds, so they are a risk be in a position where we wait for something to go money out of development or have to take money group” (P7) wrong and then ok now, we’ll drag something out of out of performance to provide a compliance performance, because otherwise we can’t carry on” officer or an ethics officer or somebody that’s got “what I think we’ve done pretty well with, over (FG1) that in the job title” (P8) last couple of years, is athletes being constantly abused on social media and threatened and “So if I’m writing bids for public money, and I’m “a lot of sports are scared of an appeals policy so stalked, we used to - as part of the investigatory explicitly not allowed to exceed a certain amount they won’t promote it to athletes, so it’s hidden, function - in other words [say to athletes], tell in that tender for our core costs, i.e. turn the lights and it’s super complicated and it’s 20 pages us what’s happened, go away and sort it out on, have a legal department, have a finance team, long, so an athlete will never appeal a selection yourselves” (F1) consider governance, I can’t go across a threshold decision because they just can’t understand the for any of our core costs, so any of our staffing, document or navigate through it so it’s trying When asked whether anti-doping or classification that’s wrong. Fundamentally that needs to be to encourage sports to make policies readily manipulation was the biggest threat to the integrity addressed if there’s going to be a genuine change in available, easy to understand for everyone who of Paralympic sport a respondent said: compliance” (FG2) sits in the NGB (National Governing Body) and make them understand running a disciplinary “I would say classification would be the biggest “… I just genuinely think there needs to be a appeals process doesn’t mean they’re a bad NGB. threat because anti-doping has more resources, it recognition that while we’re an organisation that It’s just the reality of life, there’s always going to affects the Olympic side as well as the Paralympic has these functions, and therefore when applying be issues. It’s just making sure they’re dealt with in side and it’s more established. The WADA Code for money that’s available the organisations that a fair and transparent manner” (P1) was first signed up to in 2003 so familiarity with are putting these conditions should recognise it as the issues are far more embedded and across simple as that. Because at the moment, if you apply “There is that disconnect between regional sport. It’s not Paralympic sport on its own that’s for funding from certain government departments people and HQ, we don’t really need you until driving this. Classification is, by comparison, it’s like 15% that you can put on staff, well good luck there’s an issue and I think that’s down to the significantly under resourced, it’s very much the even getting the delivery costs out of that let alone organisation as well to build up that relationship” core of Paralympic sport so we’re on our own the actual cost of doing business” (FG2) (FG2) with that issue. We can use or apply principles or policies that have been implemented for other At a more local, policy-based level others In their responses, others focused not on their integrity issues but we’re under resourced, and mentioned that existing misconduct processes or organisations but on external threats. Some it’s not as clear what your stance is. With anti- procedures in their organisations do not make it participants spoke about the strategic use of risk doping you’re against people taking drugs solely easy for individuals to disclose or appeal decisions, management processes, though the majority did to enhance performance because it’s a dangerous and time for educating athletes is at a premium not. Some predictable responses such as betting, area for athletes. For classification you’re not with integrity education not seen as a priority. This corruption of officials, and pecuniary threats were against anything, it’s actually a function that needs is further heightened when moving away from discussed. Others indicated newer threats to sport to exist for Paralympic sport to happen so you’re high performance to grassroots sport, where fewer integrity, such as classification in Paralympic sports against the abuse of that function. The function resources were perceived to be available. Simply becoming more prominent, and the effect of social itself needs to continue to evolve and grow to stating resource as a threat to sport integrity does media. Thus: better understand how athletes’ impairments are not do justice to the multiplicity of ways in which this effected on the field of play”. (P9) could be instantiated. Consider the following three “one of the woolly areas in the sport is officiating. responses: First and foremost, that is they should be flag bearers for integrity in terms of rules and “We just need to be mindful that this doesn’t regulation, unfortunately they are as susceptible come, and is a potential cost, either on getting to approaches in our sport and have an ability

48 49 Current Approaches to Sport Integrity

In an effort to understand the sporting integrity Another Focus Group stakeholder provided “risk management is really key to understand templates and said to sports, you don’t have to landscape in the UK we also invited respondents several potential educational interventions that had your risk profile is in this area. To your original do this stuff often but when you do get it right. to inform us about their approach to sport proved successful with a range of other issues, not question, our main drivers for integrity are child Here are some templates if you use these by and integrity, including details of current initiatives and necessarily integrity-focused ones. They stated: safeguarding and anti-doping and probably large they will get you to the right place.” (P1) developments. It is important to note, first, that sails down from there. In reality, and that’s also the majority of respondents in the questionnaire “we’ve done some creative stuff around education resource driven. What recourse do we have, what Not everyone, however, supported practice sharing have some form of integrity function, and of those like designing workshops to challenge moral can we focus on, where can you start? For us we initiatives. Given the potential for reputational interviewed, proactive educational approaches were compass, largely about cheating on the field of recognised that’s probably our highest risk profile” damage some stakeholders, typically those in in place. What is noteworthy, however, is that others play” (FG2). (FG1) highly economically driven environments, might utilised education as something of a compliance be expected to be circumspect. For example, one tool alongside regulatory developments; Others were more sceptical of International Another area closely aligned to education, and one respondent noted with caution: Federation approaches where lead bodies were that could minimise risk was the sharing of good “so, the answer is different depending on which seen simply to throw money at problems in order to practice and making the right connections. Here “No, I think we would be very careful … we integrity area you’re talking about I’d say on our be seen to be doing something, whether or not this are some illustrative quotations concerning the would share things with people we trusted, anti-doping side that would have been more was effective in educational or compliance terms: importance of sharing good or best practice across maybe even by word of mouth, but maybe within preventative as well along with sports betting organisations: certain sports, and certainly certain bodies within which is why we dedicate the majority of our “They give each national association £50k per ***** we use a software tool ***** which helps, resources in those two areas to education. Getting year to do with what they want. Some appoint. “But a lot of the work we’ve done is trying to these sort of charts you would see in criminal our regulations correct but once we’ve done that You have to have an integrity officer, but you don’t create resources, policies for sports that they cases where you have masses and masses of 85% of our time is education and training” (P8) have to use that £50k to fund that person. And can download and use and adopt within their data generated through phone calls, generated you’ll find the integrity officers have a massively organisation. We also run integrity workshop days through associations, who drives what cars, who Interestingly, the context for educational different function across each. To compete in the where we get experts in different areas and sports meets what people, who makes what phone calls, interventions was considered effective and efficient [international tournament], you’ve got to deliver can come in and meet their peers and can learn and ***** helps you have analysts and we now by some respondents. Here is one example: an integrity education programme” (FG1) best practice. For example, introducing sports to have three dedicated analysts in the world of the gambling commission. Lots of the sports don’t anti-corruption maintaining our database using “In the [international tournament] it’s become your One could foresee that educational interventions know anything about the gambling commission or ***** to make sense of all the data. Now we share passport very much, you need to do education would be a necessary component of policy and sports betting group.” (P1) that data***** is a pretty safe set-up to share data including team managers and coaches, or you practice development in sport integrity. Given the through” (P2) don’t participate. Being an integrity officer for the array of sport integrity issues it would be worth “We do a lot of work with UKAD in trying [international tournament] I was really surprised further international investigation as to how anti- to monitor all the anti-doping requirements Others, by contrast, looked to utilise existing tools by the reaction of the team management within doping organisations have balanced education […] Everything is resource driven because as such as codes of conduct to facilitate integrity squads in terms of they allow you a slot and made versus testing controls and examined the processes mentioned before, especially anti-doping, it’s just compliance: you feel very welcome, they couldn’t be more by which such a determination was made. Relatedly, handled by the role of someone else […] sports welcoming, it wasn’t the day of the game, it was then, in management terms, it was somewhat like volleyball and softball, that are completely “In our funding agreement we do talk about the week running up to it, they are in camp for a surprising that so few stakeholders mentioned, when run on a voluntary basis and you have someone safeguarding, in terms of bullying and stuff like long time and do have time for education, so from asked, whether sport integrity featured strongly who is responsible for anti-doping and they’re that, we would cover it under codes of conduct, our perspective on the world stage, they are very in organisational risk assessments or risk registers. just learning about it, trying to navigate their way and diversity and inclusion which comes under the welcoming and even in our club environment they Again, this may be down to the fact that integrity through it,” (P1) code for sports governance” (P3) are very receptive to education”. (FG1) elements are captured or dispersed across other areas of such documents. One respondent was clear “we introduced a set of templates based on best as to its importance: practice and indeed we had them validated from ACAS and got a gold star so we produce these

50 51 While another remarked about a useful integrity “So, all of those elements are underpinned by Secondly, compare these remarks with a culture- public reporting of misconduct and those that do supportive technique used in another sport: our regulations and the regulation of the game driven approach: not. Similarly, in the sample we found a range of sits within the legal and governance department. approaches. “So for example, he advised me of a technique And that includes everything from getting “It’s not good enough just believing in sport. We they use in ***** that if you can’t pin someone involved, if we’re making regulations advising need to make sure they have the right beliefs “the difference between the ***** and us is who’s causing you real problems, you can ban him on the regulations, getting involved in projects and right philosophy. So that backdrop to high that we don’t share the details of any discipline from appearing at your events, and then build it that have implications on the regulations, and challenge here is, clearly over the last two to three process on public domains. We will just simply in to the code of conduct of your people, who are broader through to educating on the regulations years some people are uncomfortable with the say an allegation was made, an investigation bound by your code of conduct that they mustn’t and policing them. So from our perspective our word winning because it’s been associated with was conducted, a disciplinary panel sat, and the associate with that” (P2) integrity function very much sits within the legal “at any cost” and things, so we’ve gone down appropriate sanctions were applied or something and governance department and we, well if we the root of high challenge because it fits with the like that. We don’t say an allegation was made One of the key areas that marked out the mode of were to include safeguarding within legal and phrase high performance” (P7) into ***** about bullying. The panel sat and he integrity planning and implementation regarded governance department and we, we probably was given a final warning, so we anonymise it. the regulatory approach. Although it is difficult have at any one time at least six individuals who “unlike ***** who I felt were just picking up ***** are very open, and they will put all the to generalise, the strongest commercial sport are working exclusively on some element of culture at a late stage I did some workshops results of their misconduct discipline panels on represented in the interview sample population was integrity during the day.” (P8) with our whole high-performance team and our their website therefore in the public domain” (P1) characterised by a multi-method approach, but one starting point was to challenge our beliefs, our that was legally driven. This may mark an important Elsewhere in the interview the same respondent philosophy, and our values. Because I think you Whether there are good reasons for this is a moot fault line. Clearly issues of personal integrity that remarks: need to go back to that before you can really point. Commercially driven sports may consider the are moved through misconduct processes will apply enter what you mean by integrity and culture. And negative financial consequences more seriously than employment law as a framework and tool, whereas “but we have a number of rules that focus on what came out of that, we now have a mantra that less wealthy sports. Being clear about the levels of volunteer-driven processes will not. Moreover, it is all of those things in some capacity, so the I think [is] what high performance sport should transparency and consistency of reporting, especially reasonable to assume that less wealthy organisations misconduct is very all-encompassing for us, look and feel like in *****.” (P7) where this relates to the use of public monies, seems will not make recourse to law but use alternative that’s where we would put most of our personal a clear candidate for integrity development. dispute resolution processes. Yet economic resource integrity type issues where we’re focusing on the A similar tone is struck by another interviewee that is not the only parameter that distinguishes the conduct of a particular individual or club so we brought athlete well-being into the same ambit as a stakeholders. NGBs simply have different corporate can use a misconduct charge to charge a club cultural approach: goals to Home Country Sport Councils. It is with an integrity offence, particularly if a club Although it is difficult to interesting then, though not wholly surprising, that has systematically done something or not done “There is some specific stuff at the minute with generalise, the strongest the relations between an NGB and its members will something. So, we would see that as a corporate regard to well-being, but there will be a wider differ in style and approach and powers to those integrity type case. But we probably would have project to do with all aspects of an athlete’s commercial sport of, for example, a Home Nation Sport Council and broken down like that. We tend to draft our development so that’s being worked on and [is] its constituent NGBs, or UK Sport and its funding regulations as broadly as possible to enable us as much about the environment as well, what kind represented in the interview recipients. We quote below responses from both to make them fit a number of different integrity of environment they’re in, so we’re doing some sample population was a focus group discussion between a legalistic offences I suppose, and then we do have specific practical work at the minute on parents and on rules-based approach to integrity vs a culture regulations to corruption, betting, anti-doping, well-being, but there’ll be more stuff” (P4) characterised by a multi- values-based approach, and later an interview that eligibility and fair play on the field” (P8) concentrated particularly on this topic. First, we A final point, worth noting here, concerns the extent method approach, but one present a legal approach: to which sport organisations treat transparency in that was legally driven relation to integrity breaches. The international sport landscape embodies organisations that include

52 53 Organisational Structures and Partnerships for Sport Integrity

In order to evaluate which organisations were better they really believe in it and live it? And do they within the team how this fits in to your strategic placed on their sport integrity trajectory, and to really implement it as well as they could? I think aims, your values and what your organisation consider how those better placed might assist those there’s some lessons to be learnt with that. I think stands for. And that has to, of course, be led by less far on their journey, we looked at how some you’re better off bringing people with you and the board. In terms of the regulation, that’s a of the respondents’ organisations had established them seeing it as part of their day to day job as separate conversation, in terms of independence their integrity functions, and how they fitted within opposed to imposing it on them” (P4) particularly in cricket, tennis etc what the IAAF their organisation’s structures. Even for those are doing, but nonetheless you have to take organisations with fully-fledged integrity functions, “I wouldn’t say there’s any one person that’s ownership within the sport first and have that it seems as though these are still widely dispersed solely responsible for integrity, it’s right through cross communication” (P4) across organisations i.e. not sitting in one integrity the whole organisation so there wouldn’t be one space. This is especially the case when looking at board member who would be like an integrity The last quotation draws out a key point regarding legal and ethics-driven functions, as the following champion if you like. There would be a collective the management of any innovation: the location of quotations illustrate: responsibility” (P6) responsibility. While responsibility is often thought to be a personal matter, we saw above how one NGB “Last year I think there were about four people, Building on the above, other respondents respondent talked about corporate responsibility, and this is we now have 11 or 12. That’s split commented that implementing integrity functions where a club might be held responsible for actions between sub departments, we have the legal was not affected as much by the location in the or cultures that were improper in some way. In dept, which deals with any contracts or legal organisation that the integrity function resides, this way a club is treated as a person; a singular issues so like injury claims or insurance parts, there but had more to do with having personal and entity. There are clear benefits, of course, to having is our part which is the ethics and compliance, so cultural factors such as effective leaders and good identifiable persons, often referred to as ‘champions’ we deal with all the anti-doping issues” (FG2) communication: of this or that cause, issue or policy. Scepticism of individual responsibility across institutions can lead “There’s no single defined function in the “the corporate structure is less important than to a practice of distributed responsibility, which organisation. It tends to pervade all directorates actually the conversations that happen on the is common in law (joint enterprise) and politics or business areas, or should pervade, should be shop floor, and that’s what’s got to be important, (collective responsibility) and other spheres of part of the stuff there… there’s no single function an integrity individual is embedded within the life. Here accountability is dispersed in a model that has responsibility for it, it’s definitely a relevant departments” (P3) of distributed responsibilities. When we pushed collective” (P4) one interviewee about this, we used the following “what matters is those conversations that ***** prompt “if it’s everyone’s responsibility, then it’s no “but I struggle with the idea of a single was talking about is those individuals who are one’s responsibility”. The respondent commented; department with responsibility for it. I would responsible for integrity actually work together, much prefer a very effective joint or collaborative know each other, have those cross departmental “No, I think it’s worth flagging. It’s … you can responsibility across the organisation and that conversations.” (FG1) be, not necessarily complacent, but I would say isn’t easy, and sometimes people avoid their blindsided because nobody is taking responsibility responsibility when they’re not held to account “It’s how you live it and having an individual who’s for it” (P4) properly. So, there’s got to be a process where aware of it, and it’s not just about organisation, I think you can have it collaboratively across having people who are leading aware and visible the organisation but how do you make sure to other areas, and that’s the responsibility of an people are doing a good job of that across the organisation, whether it be corporate or sports.” organisation. We face it already with some of (P7) our Equality Act stuff, as soon as you create a department for equality, people just see it as a “It’s just about responsibility within organisations. tick box or something they’ve just got to do. Do So internally you have to educate senior leaders

54 55 Clearly, then, any future strategic developments in the UK and with police investigative bodies. “identified three focus areas. One around the risks The sheer range of potential partnerships is within and across sport organisations must address That’s the sort of effective partnerships” (P2) around procurement around major events, one is noteworthy, and even this range is not exhaustive (cf the issue of personal and corporate responsibilities around major events bidding itself, and the third Cleret, McNamee, and Page, 2017). It underscores for integrity development. Parents (as noted above in a different context) [is] around the governance of international sport. the scope of integrity work, its dispersal, the And so these are all areas […] we are particularly plethora of related organisations that need It was noted above that organisational structure and “There is some specific stuff at the minute with interested in, especially the major events and coordinated action to maximise effectiveness of objectives will influence how integrity policy and regard to well-being, but there will be a wider the international sports governance and so we policy and practice development in the integrity practice is enacted. So, it is important to recognise project to do with all aspects of an athlete’s are deeply involved together with DCMS in the landscape. This point is especially important when that the UK sport integrity landscape sits within development so that’s being worked on and as running of the partnership and delivering certain considering the different models of delivery and or below an international landscape. The picture much about the environment as well, what kind pieces of work where sport is learning from other compliance in sport integrity and considering what they presented, perhaps a counter-intuitive one, of environment they’re in, so we’re doing some sectors, in particular the public sector from a elements are properly the subject of mandate, which was one where developments were not necessarily practical work at the minute on parents and on variety of different countries, but also brings may be considered aspirational or voluntary. driven by IFs but were secured via iteration between well-being, but there’ll be more stuff” (P4) government closer to sport to understand the partners both vertically (i.e. up and down; national needs and challenges that sport is facing. So to international and vice versa) and horizontally Non-traditional organisations i.e. Gambling that’s now become something called IPACS and (i.e. between different sport organisations). One Commission (when discussing their involvement in has been running for 13 months or so and brings organisation detailed how they had re-structured in future discussions) together all of the Olympic movement and other order to cater for this. arms of international sport, and then several “I’d say it’s probably worthwhile depending on multi-lateral organisations such as the OECD “Because of the crossovers of what happens if they have no more or no less influence than and Council of Europe. It provides a platform for domestically and internationally, now there other people around the table. But they’re bound dialogue and action around what needs to be is a single function around governance and to have knowledge and intelligence that would addressed” (P5) international relations, it’s two separate teams but be useful in forming an approach to this. Again, they come under a single umbrella […] so there a similar comparison would be in anti-doping Sports Betting Integrity Forum (SBIF) is a lot of stuff we’re picking up domestically that with [the] supplements and IPEDs situation. If we’re transferring internationally and vice versa of you don’t bring the health authorities and public “There is certainly a group of lay stakeholders course” (P6) health around the table and just treat it as a sports that look at this area, but I think it’s more focused issues, you’re missing lots of information that is on betting and match-fixing, and given the areas Others described how they were aware of, or were really important to people’s motivations and how have broadened” (P5) involved in, other partnerships focused on sport big and how complicated the matter is. If you integrity at an international, national or local level, just treat it as a sports issue, you’ll end up with a UK Culture, Integrity and Welfare Group including the following third parties: solution that doesn’t answer the complexity of the situation. So yeah, I think they should be around “It’s fallen out of HPSAG (High Performance Law Enforcement (in relation to event manipulation the table.” (P4) Strategic Advisory Group), so the Culture, i.e. match fixing) Integrity and Welfare Group is answerable to On the International Scene the International HPSAG. I’m particularly picking that up here and “That’s the whole series of what I’ve called MOU, Partnership Against Corruption in Sport (IPACS) quite simply it’s the “how”. So, we’re all very memorandum of understanding. So, it could be group is very active in terms of sports corruption, outcome driven, we all invest in sports for various in the case of Australia it could be the Australia with DCMS playing a very active role in representing outcomes, but what this is about is not just about Federal Police. We have a documents MOU the UK, especially around the signing and ratification the outcome it’s about the how. This is very much with them. We have documented partnership of the Macolin Convention. about leadership and management” (P7) agreements with other sports, some of them, particularly tennis, with regulated betting industry

56 57 Models of Delivery and Compliance of Sport Integrity

To understand the importance of integrity work political control and indeed you cannot be a In addition, we also found examples of where Governance was a really great first step, I think it across the UK, respondents were asked for their member of an International Federation if you existing tools such as funding agreements, can be strengthened second time around” (P1) views on how sport integrity might effectively be are subject to political control, so what you’re governance frameworks or even sponsorship audited, and what compliance processes were in suggesting there is a fundamental change to the contracts could be used to improve sport integrity A final point worth mentioning here is how, without place to ensure organisations were performing landscape if you want someone to come in and compliance. The range of responses is presented prompting, several of the respondents linked to an acceptable standard. There were many regulate” (FG2) below: integrity work to good governance. This may be due interesting comments not least around financial to the recency of the wide adoption of the Good pressure to comply with directives that came from Slightly less defensive were the following “But, that’s interesting because often if an Governance Code, or their mindset of working with funding organisations. In this regard, we found a acknowledgements: athlete misconducts themselves and they’ve got partner NGBs as opposed to the delivery of events somewhat defensive response from home nation sponsorship, then the sponsors have an even or the generation of sport rules themselves. In these and UK sports councils that was reasonably widely “so, although we’re trying to safeguard the use greater effect on their conduct than we possibly cases, competition integrity is not seen as directly shared. Respondents from these organisations did of public money, we’re also trying to encourage could.” (P1) within their scope. What is not acknowledged is the not see themselves as regulators yet acknowledged sports to think broader and improve themselves scope of integrity work that falls outside of a good that they had a substantial regulating lever in the as organisations, so that will cover finance and “I think we’re getting ourselves into a reasonable governance framework. distribution or withholding of public monies. The HR and how they manage their policies. Some of space now where we’ve got a trusting dialogue following are comments from home nation sport the conditions we expect for public investment with the sports where ideally we can intervene In the space of discussions concerned with models council representatives. we do expect them to meet certain safeguarding early if needs be. We do have a power in of delivery and compliance, the availability of standards, we go into more detail with that the funding agreement to commission an resources again arose as an issue in relation “Well it’s a conditional award. It’s a funding and we do expect them to meet the GDPR investigation into any matter we choose should to compliance, both from the perspectives of condition in an award agreement. So, to receive requirements. There is an anti-doping compliance we need it, but we haven’t had to” (P1) “regulator” and the “regulated”. A proactive, public money they have to comply with the code requirement, there’s also a sports betting policy principle-based approach dependent on resources or have an action plan in place to comply. So, it’s a requirement, so we do touch on that. And then “yeah I think once you get to deciding what it is, was proposed by some, and from a regulator condition of award. Award being the money they internally we obviously have legal and finance what it looks like, yeah it makes sense to make perspective, it was suggested more of a risk- get.” (P3) teams and we work with those closely and some it mandatory, because we’ve got various codes based, supporting approach would be more of that’s for us but also get their advice on how we both internationally and nationally we’ve got the beneficial. Their views are nuanced. Here is one “Yeah, we don’t have any role beyond that, our work with our partners” (FG2) Sports Governance Code, so evolving that up to that points out the nature and level of the activity only lever is public money. And there’s a variety of beyond sports governance into integrity, because is not of overriding importance when it comes to different options, you could change payments to “Obviously, the challenge we have here is in some sports governance looks at ensuring people safeguarding: monthly in arrears, and nuclear is probably we’re instances we can police and enforce it, and we do, don’t have capacity to abuse their position if you not going to fund you, but reputationally there so for example, all the governing bodies we invest like, but what I don’t think it can do is measure “So, I don’t think a child taking part in would be other things going on” (P3) in, we insist they have clean sport policies and that integrity and measure that sort of, I think orienteering should be any less safe than a child processes and that they are compliant. If they are you need something else to really measure and taking part in organised football but how you “we are of course an investor not a regulator” (P1) not, we can intervene and threaten to withdraw capture that look and feel.” (P9) would go about that and what would it look like in money. It’s the same with anti-bribery and illegal those two situations would be different. So for me “We have an obligation to make sure that the betting. The grey area here is when it comes to “I think in a couple of years’ time this is probably the outcome is actually there is a safety that we’ve money we invest is spent ethically and ensures the how people behave, dismissible behaviours, then worth updating, and I think we can put a bit got, that people know what they need to know, highest standards. That is the lever we use. We [it] starts getting in to a grey area, and whilst we more detail around requirement [specific and how stuff gets handled will be down to them, are sort of regulating in our assessment. That’s a don’t shy away from addressing things, we have to regulation] which is having appropriate policies but for moderate sized NGBs that have got some small ‘r’ in regulation” (P1) be careful we’re not policing ourselves the same and procedures in respect [of] its obligations for resources but aren’t as well-resourced as you time we are writing the policies” (P7) looking after people. I think we can tighten that here today, where response would mean putting “NGBs are responsible for running their sports, up a bit, because it all refers to safeguarding, more money into something, which is fantastic, the principle we run from in this country is that whistleblowing etc, so I think the Code for Sports but impossible at the other end. So, from a sports are self-regulating and do not come under

58 59 safeguarding and integrity point of view overall, and responsibilities and duties are. You talk about always be grey areas and subjective, it’s not clear topics from one category to another. Recently what should people be addressing rather than this culture; it all plays into culture. If people don’t cut and that is difficult” (P3) with the social media side of things we’ve is the model, and how can we take this model and understand how to treat people properly, they escalated it to category B. International squads apply it to *****. But you might be saying ***** don’t understand what the mechanisms are for One of the values of a focus group approach is to and professional players have more education still needs to have their own arrangements” (FG1) calling stuff out, if people don’t understand how reveal practices in one population that others had on that side of things. Cultural awareness I think to deal with things quickly and efficiently, then not considered. The following description garnered has moved up to B. Some of it can be reactive, Here is another response that says resources dictate [there is] the scope for conflict to escalate and the considerable support. One sport discussed how some of it is proactive. Category C topics are effectiveness: more it escalates the longer it takes to resolve. it attempted to prioritise its educational agenda things like agents, what to look out for with agent Often the worse it gets. So, it’s all about dealing according to the significance of the ethical or relationships, financial management, pension. “We’ve got one of the wealthiest sports with things early and one of the areas we have integrity threats. The point was pursued by others Recommended but not … they generally won’t governing bodies in the country. It has a identified for further investment over the coming in the focus group and later became the object of have a player welfare implication if things go dedicated intelligence team that dwarfs the six months is increasing the capacity within the an extended discussion within an interview. The wrong. It won’t be pleasant, but not a matter of Gambling Commission’s and that’s just dedicated system for mediation” (P1) discussion progressed into whether there should be life or death, like some of the category A topics. to one sport. It’s got analysts, it’s got investigators, a tiered (i.e. prioritised) approach to sport integrity. That works for us. We’ve done that really recently. it’s got a national reach and you compare that When use of resources and scope of powers It was important to note that prioritisation was We ticked that off about two and a half years with something like British Tiddlywinks which is was considered by one respondent, they gave not presented as a way of avoiding certain issues ago, it’s a new thing for [their sport]. It took us a Barry working out of his garden shed who still consideration to the levels of seriousness or or pathways, but as a pragmatic response to the long while to get there and it’s not necessarily the has the same legal obligations and compliance significance and whether legal responses were allocation of resources that, even in wealthy NGBs, answer, but it’s certainly worked for us, and not obligations, observant of GDPR etc” (FG2) proportionate. They argued for increased use of was likely to be outstripped by demand. They least because it does free up a chunk of time” (P8) mediation rather than legally driven responses discuss their risk-management driven process as Another offers a response to resource differences like arbitration. Deciding which routes should be follows: Another responded with an emphasis on inclusion and a partnership model of development. What is followed, whether through (e.g.) Sport Resolutions, and buy in from the relevant population: especially important, given our elision of commercial with which many UK sports organisations have direct “so, we have done that, and we have integrated sport with legalistic integrity approaches, is the or indirect (funded) access they remarked: the programmes and the education and identified “yes, I think there should be a tiered approach. I idea of alternative dispute resolution which may those three topics (anti-doping, sports betting, think there’s some legal ones that we really can’t be perceived, when appropriately targeted, as less “it depends what level they want to go to… concussion) of being of highest priority for avoid, there’s some fiscal ones, other legal ones expensive and quicker. Sport Resolutions has a lot of arbitrators but our professional game. That’s not to say we we have to have, because we’re dealing with doesn’t have a lot of on the ground mediators forget safeguarding and all that sort of thing, public money in terms of our organisation. They “The oversight is very light touch in as much [as] who have that skill set to be able to talk to the that’s almost dealt with separately by different have to apply those kinds of checks and balances. we require NGBs to write to us each year and athletes.” (P10) individuals within a professional environment, I suggest a tiered approach is sensible, but I also confirm they are in compliance with the funding and we do separate work on that, but in terms suggest that designing it with the people it’s agreement. I think we can be more specific in A pragmatic balance is struck by the following of those three topics we educate the clubs and going to be applied to is sensible as you get a terms of what we want them to inform us about respondent: the players and team management together better buy-in and better information and decision and I think it would be beneficial if once a year we now, and what that enables us to free up time making as a consequence of involving them early. met with each of the NGBs and I sat down with “so, I think we wouldn’t have the resource or to educate on a whole range of category B Not being beholden to everything they might them and went through their processes and went capacity to monitor closely, neither would we type topics. So, we have category A, B, C and say because there is a degree, or there can be a through their history of what they’ve done over want to because that would make us a regulator, D topics which go from being mandated (three degree of self-interest in some of those partners the last 12 months and so it wasn’t just a case it wouldn’t be our job to do that, but it’s using a mentioned), so that’s their passport into the so we need to be mindful of that, but involving of tell me, it was a case of show me. So much of risk-based approach. Even in the integrity space, game every summer. Category B are strongly them early and helping them co-design it is very the issues around conduct and conflict in these because it’s unclear what actually is it, there might recommended topics, things like addictive sensible and a tiered approach likewise” (P4) environments stems from poor induction and be room for people to play in and around grey behaviours which cover a whole range of things regular refreshes of people on what their rights areas, like in selection processes, but there will including gambling awareness. We can escalate

60 61 Finally, another respondent acknowledged actually the culture that has changed in governing investigation were added onto the governance the problem of prioritisation in a result driven bodies over the last seven to eight years has been action plan and it was expanded to take care of environment for high performance sport, versus a very positive and many of them want to comply that” (P1) mass participation perspective: because, comply is not the right word, they want to improve best practice”(FG2) “Mandating something is helpful for a sport to “That’s a fascinating debate. Is that more have regulations and hooks upon which you important than the integrity of competition? “For a UK framework, UK-wide buy-in, I would can put things as and when you find out about Personally, I would think yes because I’m a father argue probably that you’ll need to go down a offences, whether through proactive intervention and it’s also part of our culture within society that framework approach, like ***** have done with or policing, or reactive. The other thing not to we don’t harm children. I’m not necessarily saying governance versus a doctrinal sign-up approach forget is for a sports regulator it’s as much about we have the same culture that we don’t cheat in like the UK Code for Sports Governance which educating as it is mandating, so if [it’s] the carrot sport, not everybody does, but some people do. was comply or die basically” (FG2) and stick approach, we try to get a good balance Really difficult, I like the idea of a framework, but I of both” (P8) think it’ll be really difficult to nail this and say this “I’m for a framework and I think we’re talking is compulsory, this is optional. I think by having about really challenging issues that may be It could be asserted, with some justification, that a framework and having it discussed, is how you different for different sports and be different a multidimensional model of implementation and actually implement integrity, so people start to for different issues. It’s people. So, my level of compliance was entirely predictable. Nevertheless, think is it acceptable to fall over in the box? Is acceptance of bending the rules will be slightly it is important to emphasise this is what the key it acceptable to whatever it might be to push different to everyone else around me” (FG2) stakeholders in our focus group and interviews a young athlete in a performance programme have recommended and thus believe will be beyond what is actually what they are physically “I think you need to mandate a policy; you successful. The devil, as the saying goes, will be and mentally capable? And then there are others need some mandated process. I think you need in the detail. What kinds of sticks? What kind of who say if you’re going to get a gold medal that’s guidance, and you also need judgment and that carrots? Also, it will not be straightforward to work what you have to do. Some will say it’s acceptable judgment often requires both experience and up a national agenda. Having said that there was if you want a gold medal and others not” (FG2) also training… So, discipline, grievance and a clear commitment to partnerships working, the that, would be for athletes and members of staff issues of leadership and ownership are likely to be These comments above bring us seamlessly to the because there are subtle difference there, then thorny ones. How, and when to develop an effective final meme in this topic, of whether a tiered (i.e. you want one around whistleblowing, and you strategy that determines the priorities after legal prioritised) approach justifies the decision regarding need to mandate a policy around diversity and requirements have been addressed. Given that mandatory elements (e.g. safeguarding, and child- inclusion. And lastly, selection and independent 2020 is a Summer Olympic year and is likely to be protection are obligatory for all) and/or should the elements” (P1) the focus of national media and public attention on approach take the form of guidance with some results more than performances, these issues are elements acknowledged as legal requirements, “both Sport England and UK Sport have urgent and require critical attention. while others might be strongly advised and a final governance managers and each of them has list that would only be aspirational. Every participant a portfolio of sports, and they work with those in the focus groups and interviews was supportive sports to ensure they are compliant with the of a proportionate strategy for sport integrity. Most Code. Where they’re not compliant a governance respondents preferred a hybrid model that had built action plan is developed and [they] monitor them in flexibility, incorporating elements of both a ‘carrot in delivering on that action plan. So as an example and stick’ approach. For example: I referred to this investigation we did into an NGB, as part of that investigation an amendment to “the approach we have in ***** is a governance the governance action plan was produced so that framework, which is more, it’s not mandatory, and shortcomings that were identified as part of that

62 63 Future Developments in Sport Integrity

The final element of the research was to capture “I think it’s important each of us know what the dimensions, acknowledging that good practice has There was also reference to looking beyond people’s aspirations not only for clarifying the sport other is doing and filtering that resource in terms been made in several areas already: traditional education programmes with sports integrity landscape across the UK, but for improving of what’s working and what isn’t, and any new organisations and tackling the root of the problem in it. These discussions were not entirely separable method that’s being used” (FG1) “I think the integrity functions of a sport need to schools and with parents. from the issues that arose above. Nevertheless, work together. So particularly [the] education side, we have created a distinct theme that can serve as “I’m early on in my career so if there was I mean where we are, correcting slightly there, “Imagine a football match where you go into it a segue into the recommendations. Discussions somewhere where you can post a question on in terms of proportion of our time and resources where there is a learning outcome for kids which around planned and aspirational developments for there and keeping it confidential that - any ideas we spend more of our time and resources on is based on resilience. The way you ensure they the future centred around sharing best practice, how I would deal with this issue” (FG2) education rather than regulation compliance side. learn that is you know that your team is going to education, clear mapping of all existing groups, and And I would probably say 70/30 on that. I would suffer at least three deliberate injustices during the formulation of a UK Sport Integrity Forum. “the approach I would take is what’s achievable, say to sports which work, anyone working on the match and during those points in the match you know starting from that. What’s desirable may sports betting and integrity and agents, work with ref pauses the game, you have the opportunity Can we talk about good or best practice? This not be achievable at least in the short term and and along[side] those working on anti-doping, to debrief and discuss how you’re going to distinction has been used in the anti-doping therefore my approach would be let’s start with and actually treat integrity as a broad number tackle it. So, you’re kind of using competition in literature to capture the confidence of stakeholders something like a forum with agreed principles of subject areas rather than have different silos different way. There’s all kinds of innovative stuff with various different aspects of clean sport policies that nobody can object to, ok it may be a little working on integrity, on anti-doping, player out there that you can do that I think will be quite and practices. Perhaps some specific policies bit motherhood and apple pie, but let’s start registration. Have individuals who are across all interesting” (FG2) are capable of authoritative guidance. Yet, given with at least coming together, let’s start sharing of those areas and can work together to get that cultural variations on a global scale, can we ever databases of intelligence, because what I’m time in the club to educate on all those areas all at “this goes beyond sport. It starts in the home; it meaningfully talk about “best practice” in the certain of, on one occasion we managed to ban once if possible” (FG1) starts at school. It starts at such a young age. I singular when it comes to much of the issues that a guy who owned a team in *****. So, we had don’t doubt there are people playing professional comprise sport integrity? For the purposes of this him banned from ***** for life for trying to fix the Similarly, another responded: sport nowadays that wouldn’t nick a pack of report we elide the distinction and do not adopt a whole tournament and we got enough evidence McVities Digestives from the corner shop” (FG2) specific stance, except to conjoin the two. by where he was banned. What did I learn within “Yeah, exactly, because actually integrity, two or three months, he bought a ***** team. regardless which area you’re working in, the “It’s not until I’ve been listening around the table With regards to sharing good/best practice, many Now do you think that’s because he’s interested themes are very much the same. Education is key. today, I’m thinking, yeah. There are times I’ve respondents noted that it would be good to have a in *****, or he’s interested in gambling and the Communication is key, having good regulations dealt with ***** or ***** or people like that where platform(s) to facilitate this along with creating user opportunities for gambling. That’s my point, these is key and having a good disciplinary process to they’ve had a guy who’s got into a fight and so friendly integrity guides and sharing intelligence, fixers run across sports. We have to work across discipline individuals as and when we need to is there’s other elements of integrity they’ve got to something which the Macolin Convention may be sports” (P2) also key. So the themes are all very similar, the deal with, but I am incredibly task focused. I’m able to assist with in the future. subject matter is different but the themes are all just concentrating on my task in hand, rather than Finally, one respondent pointed to the guidance very similar, and recognising that is the key, you taking a step back and seeing the bigger picture, “my view would be sharing best practice sharing already offered by UK Sport with respect to template don’t have to necessarily have someone who because there are other elements that we need what we do is a really good idea, and I know policies for misconduct that gave clear guidance specialises in anti-doping or sports betting, you to contribute. There are parents that need to we’ve learnt a lot from groups like the sports about setting up robust processes to achieve can have a number of individuals who specialise contribute.” (FG2) betting group, a team sports anti-doping group, integrity related outcomes. in a number of those areas and able to work there’s all sorts of little groups set up where across them all and pool resources accordingly. “Our anti-doping education needs to be geared we share what we do and I know I find them Another critical component of future developments, That’s where I think we can somewhat address the towards teenagers or it’ll be too late. We need a tremendously useful, the contacts and learning stated by several respondents, was being resourcing challenges sports have, including the way of working collectively with schools and all best practice, for us we just tend to say, this is proactive, especially in offering effective education bigger sports and I include ourselves in there. We organisations could do this in some form. Generic what we do, what works, what do you do, do you programmes and pooling resources. This have resourcing challenges all the time” (FG1) education in schools, not really sport specific.” know that works well for other people? We are respondent in particular focused on efficiency (FG2) now interested in it” (P8) gains by looking at synergies across the integrity

64 65 “We’ve got an app for parents of talented really important missing element of the process, outcome, so I don’t think it should just comprise “I think you need really good leaders there. I think athletes which at the moment focuses more on because people get inducted to an Olympic massive advocates and nothing but advocates the danger is if you don’t just want representation the development of the adolescent brain. We programme at the start of a 4-year cycle but by because you won’t question potential outcomes from certain organisations, I think you want good could easily have integrity of sport as a block of the time they get to year 3 when the pressure is as well. I think you need, not nay sayers, but leaders there because otherwise you’re not going units with three learning units based on personal, really coming on, because they’re lining up for people who are willing to throw some questions in get the level of commitment and discussion that’s organisational and procedural integrity, or selection they’ve probably forgotten all of that to see if it’s the right thing being done” (P4) required. So straight away I mean UK Sport, safeguarding, doping etc.” (FG2) stuff.” (P1) Sport England, all the National Sports Councils, I “The challenge is to map that out to the different would throw in that group as well probably DCMS Others commented on the need to focus training “I talk a lot to coaches about bullying and I say areas and stakeholder groups” (FG1) and then look at other parties that are relevant and continuous professional development on culture to them, the trouble with bullying is people think to our high performance environment such as and behaviour: it’s a box you tick and that’s it, I’ve done that Further issues arose, however, in specific relation the Commonwealth Games Federations and and heard the lecture and move on. ‘It’s not: it’s to purpose, composition, independence and quite simply I think one needs to look at people “I would say they need to call it a suitable priority, persistent vigilance. Because bullying is a normal leadership of such a forum. The latter elicited a here. What’s going to make this work is people they need to make sure everyone understands the state of affairs in a number of situations and if multitude of commentary, not least because of the who understand this environment and, in my processes of how you look after people, they need there aren’t some safeguards in place people politicised nature that such a forum would be unable experience, not many people do. So even though, to make sure they match the investment they put will very quickly revert to bullying behaviour. I’m to avoid. Several stakeholders queried whether the I’m suggesting one needs to look at the political in to technical coaching into emotional intelligence absolutely with you, I think anything like that, funder of this research, UKAD, had a vested interest landscape, inevitably the danger here is that if you (soft skills), encouraging coaches to have difficult that can create persistent vigilance within an in leading developments in the integrity sphere. don’t get the right people who understand this conversations, better understanding of stress and organisation is really important and is an area in When the research team informed them that they area it could hold things back. So inevitably you’re mental health, which I hasten to add is happening. our coaches that is woefully neglected” (P1) were not aware of any such expansion of UKAD’s going to have to target key people who hopefully So, it’s focusing on the soft people skills [rather] than role, a more open discussion tended to follow. are respected within the system, who you know the how do you jump, run and shoot, which has Participants were keen to understand the full Sample comments included: can come tighter and make things happen quite been very much the priority. I think those would be nature of current/existing working groups around quickly” (P7) my key areas, and the last point is, I think I used to integrity, prior to progressing with any new “Who should lead on it? It is an important point refer to them as independent points of reference, I plans and potentially duplicating or ‘reinventing because they obviously need to be respected, “operationally I would see DCMS possibly setting used to say to *****, have a couple of independent the wheel’. The desire to create a UK-wide they also need to effectively not be seen to have it up and maybe funding it and getting buy-in on points of reference, people who know they can tell Sport Integrity Forum was unanimous. Support any personal or organisational interest, because a national and international perspective. Because you what you need to hear and your door is always came in several forms and was qualified by the that is a difficult one then because someone has once you write terms of reference and remit, open and it’ll never get slammed in your face and respondents in line with their own organisational to put their head above the parapet. It might I think that group could have an international you will respect their confidence and their judgment needs. Here is a sample: be worth looking at other similar scenarios in dimension as well as a, who’s to say it couldn’t and reflect on it.” (P1) history. How have certain complicated things been have a continental dimension. It could be “so, in terms of when you complete your resolved successfully, how did they go about it? responsible for Europe or UK, I obviously haven’t “we need to remind people at the start of each landscape of what exists now, I think it would be Who were the key players? How did they lead it? thought this through but if it was just within the year, this is how we treat people, this is about a tremendous step forward to have a UK-wide How did they appoint someone? I haven’t got UK DCMS would have to be involved. But I would diversity, if you’ve got a grievance this is how you Forum as a first step to see what we could agree an answer as to who, I just think the principles see DCMS once it was established just receiving make it, here’s the policy, here’s the guidance, across” (P2) of potential independence, or some sort of reports, because what this group would do then actually just making people more aware has independence, some sort of standing within the would be an advisory group on one level, but two benefits. One, if you make people more “I think any sort of forum like that would be useful. sector and within this area of integrity is probably also sent in to quality assure, spot check, and aware it just reminds them of how they should Clearly it’s only as useful as the membership of paramount, but it won’t be easy. There are bound in some instances police our system, because be talking to one another, but secondly, if there the forum, so you obviously need, you certainly to be some good people out there, but they ultimately what we’re trying to do here is protect is a problem, they know how to deal with it and need people who would question it as much as won’t be very well-known names” (P4) the integrity of sport” (P7) they start to deal with it quickly. So I think that’s a people who support it, because you’d get a better

66 67 “Potentially. That could be something they (DCMS about who is delivering what. So for me there [staff]) could facilitate. I know in the past they must be clarity of purpose, clarity of roles and have showed a lot of interest in the sport betting responsibilities, across all these stakeholders and side of things and probably in other areas as a grown up conversation: so, ensure that the well that I might not have been directly involved athletes and … the important stuff is being looked in myself. Certainly, they have come to some of after, not, people’s ideas of; this belongs to me our meetings in the past on our sport betting versus… the other thing belongs to me as well”. side, so I think they do have an interest. What I’m (P10) not quite sure about is the relationship between DCMS and Sport and Recreation Alliance for It was clear that DCMS was cited several times example. But yeah, quite who should oversee a by respondents as an entity that could play a forum like that I’m not entirely…” (P8) leading role, although support for this idea was not unequivocal. Others mentioned the Sport and “it’s relatively new territory in understanding the, Recreation Alliance, or indeed UKAD. Clearly, it is I suspect the roles and responsibilities of each beyond the scope of this research to make specific and every organisation which have a specific anti- recommendations here. Equally clearly, some kind doping or betting focus, so I could see potentially of national strategy plan will need to be drawn UK Sport being a little bit more neutral than together and funded. Which oragnisations and having a specific, as an organisation, specifically sources of funding and leadership emerge should set up to focus on an aspect of sport integrity. I follow as a response to this report. do wonder whether this is something that one would look to government and particularly DCMS Nevertheless, one respondent was already planning to play, if they don’t play already, a really active a local forum that could feed into a UK Forum: role in coordinating this forum, that should be the case. Because effectively, I think DCMS has got its “I’m going to probably speak to my directors hands on, its funding many of these organisations about whether we do need to set up an integrity and is involved both domestically and at an forum or group, because we’ve got all the various international level. And I just wonder whether it elements. Because the legal team [members] would therefore [be] an automatic you know, body probably don’t see themselves as integrity, they’re that would be suited for coordinating this forum. doing legal stuff. We’ve got a clean sport working But if so, then it would have to be appropriately group which I’m on and then there’s other bits. resourced and deemed important enough to But I think we can pull some of that together. be near the top of DCMS’ agenda. I’m not sure Ideally a vision I would like us to start is to start whether that’s been the case” (P6) using this language with governing bodies. As you well know we have the UK Governance Group “there are a lot of people and organisations [who] and I talk to governing bodies about governance do similar things. There’s not a standardised and maybe we need to think about governance approach to this. What I strive for is… I am not and integrity” (P7) bothered about if I am about mediation, or resolutions as long as the athlete […] gets the best service available and they are not confused

68 69 The same respondent questioned the need We note this view was not widely shared. Indeed, In terms of principles of procedure, it was seen “this public process of having commissioners, for a completely independent body to monitor this was the only comment that specifically to be important to some interviewees that any the Children’s Commissioner, and Older People’s compliance to sport integrity across the UK. advocated an investigatory function for the developments were not imposed on the sector Commissioner, I don’t know how successful those proposed Integrity Forum. Much more prevalent but developed with it, with specific mention of the have been because I’ve not examined their rationale “I think if you were going to set up, I think straight was the notion of evolving partnerships. It was clear importance of athlete involvement. or what they’ve achieved, but that might be another away I would agree with you, I think what’s missing that any potential forum could then be a vehicle to approach worth looking at. Does the Commissioner now is if you asked the question, so how close connect and communicate across the national and “It’s been designed by the sector and not imposed model work? Would it apply here, even if they have are we all to what’s going on, and the answer in international landscapes. Thus: on the sector so that’s the other opportunity” (P4) work in those other areas?” (P4) some instances, well maybe we’re much closer now because we’ve done all this. But how close “I think sometimes we can be quite insular and “My aspiration would be to get the athletes on That an Integrity Forum should be established was was UK Sport to British Cycling? How close was be good at dividing things up, but I think the board with that. The development of education will an unequivocally supported proposal. This however, British Cycling to what was going on? Clearly in reality of how integrity, or more specifically around be there, and not having to force athletes to do it.” begs a litany of questions: How it should be the past everyone was clearly outcome driven governance and anti-corruption stuff, is a running (P3) formed?; with what scope and powers?; who should and weren’t necessarily having spot checks or thread across different areas so it becomes lead it?; with what degree of independence from dare I say it, being policed or quality assured. I you’re fire-fighting everywhere, and what you’re “for us it’s about ex-athletes that they look up to existing sporting and governmental bodies?; what think there is a strong argument now under the potentially doing is reducing the effectiveness of and they can connect with in some way. And that’s a governing structure would be most effective? These umbrella of integrity to ask the question, should what you’re trying to ultimately achieve which is challenge but can be like an alumni network that you questions must be addressed after this report has we occasionally be quality assuring our system a stronger, more robust sport integrity, awareness engage with each week. We’ve had some significant been disseminated. in terms of, not only culture but integrity, and within the UK and at an international level as well. challenges. The whistleblowing work we’ve done if the answer is yes, and I think it is yes I think I think there is value in that definitely” (P6) on the back of some instances have proven quite it’s probably wrong to say that we can do that successful, but it’s also not just about the athletes on ourselves, because it would be no different from This comment was developed in another interview world class programmes, it’s about staff and them the police investigating the police and the public regarding an example of betting integrity. It was understanding and spotting issues, it’s engaging and challenge. So I think there is, I think a discussion thought that other countries had been more coaching the coaches to be able to identify what should be had, is this the right time to have an proactive in criminalising some integrity breaches. key problems are where in safeguarding, betting, integrity group or forum whose responsibility I It is noteworthy that the examples used were all integrity etc, there are things you can do in that think is to dare I say it, police and spot check, and Commonwealth countries: space as well but it’s really down to the sport how quality assure on an independent basis? And at that sport runs. One of our big worries is where the same time, I think whenever bad behaviour “countries actually passed criminal legislation to safeguarding sits. My view is that it’s separate, if happens that group could then go in and prevent manipulation of sport to facilitate illegal you lose it under integrity banner or heading the investigate. I mean the challenge we have at the gambling. Here in the UK I’ve been pushing for that message may be lost, that’s a little concern for me.” moment is there is no group that is responsible through our, you know the Select Committee and (FG1) for policing FIFA or Sport Wales, or Sport culture and sports etc, but they think at the moment Scotland really. I mean we’re all answerable to our that the bribery legislation we have here is ok. I’m Finally, and possibly the most radical suggestion respective governments but at the moment I think not so sure that it is ok. We have a case coming off from our sample, was a proposal to lobby for we need to have simply an independent body in October and I’ve asked the QC to look specifically or create a sport integrity commissioner or that at times of bad behaviour or bad leadership at the adequacy at the bribery legislation in dealing ombudsman. In this regard, the respondent was comes down quite strongly” (P7) with corruption and sport and whether there’s mooting a recommendation similar to one of something much more specific like Australia, New Baroness Grey-Thompson’s recommendations in Zealand and now South Africa have passed. We the Duty of Care in Sport Report, which has been have found it very helpful” (P2) pursued in non-sport contexts:

70 71 Summary and Recommendations

Delivery of, and compliance with sport integrity We are mindful that ethical innovation cannot be although they are a commonly applicable approaches to delivery. It should seek to aspirations, requires more than top down regulation. forced on unwilling minds or organisations. Each cycle for planning within the sports system. drive consistent messaging and content on Crucially, it cannot be reduced to a tick box exercise. of the recommendations below flow from our culture, values and behaviours. It should There must be a layered approach that combines discussions with stakeholders and are respectful R4. Membership of SIF to include a representative seek to utilise and develop evidence based education, regulation and cultural development to of their views. In attempting to develop a national sample of NGBs, Home Country Sport strategies and build on existing leaders in drive sport innovation and, where necessary, reform. agenda we have selected those that garnered Councils, and other relevant bodies such the field. Enhancing policy and practice in sport integrity must strong support and were identfied as areas for as UKAD, CPSU, Gambling Commission. aim beyond merely staying just above the bottom development of sport integrity functions. Our The membership should not be limited to R12. Consideration should be given as to how line. It must also be fit for purpose recognising the approach should be considered as those of a critical political representation but also should be strategic educational delivery can be formed levels of sport and its significance. While common friend. competence based. across sports levels (eg primary, secondary standards can be short in a number of integrity schooling, academy, professional) in order elements, a one size fits all approach should be With this in mind we recommend specifically: R5. The development of links to internationally for it to be credible and meaningful to the eschewed in favour of fit for purpose variations relevant bodies should be a short term goal athletes, administrators, coaches, and so around a common model, that should be driven by R1. A Sport Integrity Forum (SIF) should be in order that SIF gains international credibility on, involved. Home Country Sport Councils a national strategic plan for sport integrity. established as a first priority. The SIF from its inception. should be encouraged to develop this must include elements of independence alongside the Physical Literacy agenda. The first step of developing a sense of urgency from sport stakeholders in line with good R6. There is a pressing need to agree upon the across the UK sporting landscape was instigated governance. The SIF must be seen by conceptual boundaries of sport integrity. It R13. UK Sport/Home Country Sport Councils by the initial meeting hosted by UKAD in stakeholders as a platform for discussing should provide a definition of operational should seek to identify how organisational November 2018. The unequivocal support and key issues and agreeing priorities/work plan. value to sport stakeholders. integrity can be built into good governance recommendation for creating a UK Sport Integrity It will also be used as a platform to share developments. This might include the Forum must be seen as the second step in forming a best practice, with a clear communication R7. The operational definition should be based development of ethical audit tools, tailored powerful coalition, but crucially this needs the right plan of disseminating information to all key on a 3-dimensional model incorporating to the nature and size of sport organisations. leadership and support from key/influential people/ stakeholders. It should seek to identify the Personal, Organisational and Competition organisations. The Forum must create a vision for prioritisation of its efforts from the continuum Integrity. R14. UK Sport/Home Country Sport Councils reform and innovation, and communicate this vision of mass participation to high performance should seek to empower NGBs by providing on local, national and international levels. Once the sport. The identification of funding sources R8. It (the definition) should be supported by a working models of ethics committees, and to above has been established, the group can focus on and leadership for the development of a simple guide that shows how elements of provide appropriate training thereon, based empowering action, creating quick wins, of which national sport integity plan is critical to this sport integrity might be combined in order on existing models from outside sports establishing the Forum and creating a clear concept first priority recommendation. to create synergy and minimise overlap and such as the finance, healthcare, and police of sport integrity will already have been achieved, cross-purposed activity. sectors. then building and embedding positive change R2. Organisations with the responsibility for throughout the sport integrity landscape in the UK. allocating funding to sports organisations R9. The definition, and the processes to secure R15. UK Sport/Home Country Sport Councils should consider prioritising investment into agreement on it should be approved by the should reach out to the more commercial core integrity and governance work, or SIF. sports which already employ risk assessment risk organisations continuously prioritising tools in order to evaluate integrity threats, in participation and high performance. R10. The SIF should create an online portal for order to guide good practice in smaller, less information sharing, including elements commercial, sport organisations. R3. The initial remit for SIF should be to discuss where confidentiality can be assured. its scope and function, and prioritise key actions around short and medium term goals R11. The SIF should develop an overarching in the form of a national strategic plan. These Education Strategy that seeks to pool need not be determined by Olympic Cycles resources and encourage networked

72 73 Limitations

R16. In order to achieve greater standards R22. Sport organisations are encouraged to Research takes various forms, and the idea of a responses to some questions was not as strong as of consistency UK Sport should expand ensure sport integrity elements are visible singular ‘gold standard’ methodology does not others. Given, however that the research targeted its template policies for misconduct by and considered on their corporate risk exist. Each research method has its strengths and a necessarily wide range of stakeholders across advising on when alternative methods for assessments/risk registers. limitations. Moreover, the timings of research, the the UK, the researchers required broad questions dispute resolution should be pursued. This state of mind of the participants, the political milieu in order to provide as many respondents the would range from mediation practices, R23. Where integrity functions are dispersed at the precise time of the interviews, and so on, possibility of being able to answer. The aim of the to arbitration, and legal processes as throughout, organisations are encouraged to cannot be controlled. It is worth re-stating that the questionnaire responses was not to provide highly appropriate. bring together relevant “integrity” officers focus groups and interviews were conducted under specific information about the operations of each on a regular basis so it is seen as a corporate conditions of anonymity and confidentiality, allowing stakeholder, merely enough to map structures and R17. UK Sport/Home Country Sport Councils not individual responsibility. participants free rein to say exactly what they wished personnel, and to illicit the key areas to explore in must develop a co-ordinated approach to to. more depth during the focus group and interview the use of funding levers to support integrity R24. Finally, a number of strategies will be stages. function development. To do this will require needed to embed integrity awareness. Nevertheless, the principal limitation of this study some form of monitoring or audit that Again, good governance protocols can be is that it is a relatively small-scale investigation, The final limitation of the study was that there was should be consensually developed. used to develop the integrity agenda. Board albeit of important highly-placed stakeholders’ no direct athlete voice/representation. Rather, the Members should be encouraged to become attitudes and beliefs. The responses are thereby voice of athletes was captured with past national R18. All sport stakeholders should consider how champions of Integrity for their organisation. partly structured by contextual factors. This study, and international athletes participating in all three to develop a consistent strategy with regard especially in its qualitative elements is not, by stages of the research, and from one representative to communications and transparency in its very nature, generalisable across all UK sport body for athletes among the many that exist in the relation to integrity breaches. stakeholders. Greater resources could be directed sporting landscape of the UK as part of the interview toward a larger group of stakeholders over a longer sample. R19. Home Country Sport Councils ought to period, which may yield new data. Given, however, consider developing criteria for modelling the large degree of convergence between the good practice in (e.g.) small, medium stakeholder perceptions this is not taken to be a and large NGBs in order to develop an very significant concern by the researchers. understanding of a scaled response to resources needed to deliver sport integrity The short timescale in which to conduct the research functions. also meant some key individuals were not available to participate in either focus groups or the more R20. When developing sport integrity officer detailed interviews, nevertheless, this should not roles, consideration should be given by SIF take away from the very detailed data provided and to standardise job descriptions, and identify analysed from influential and significant stakeholders key knowledge and competencies. from a wide range of organisations across the UK. The recommendations provided are unable to R21. Attention must be given to considerations go into great detail but provide a foundation or of power by all stakeholders, particularly platform on which to confidently move forward with in relation to the consistent investigation, ambitious/aspiration plans for sport integrity in the reporting and censuring of integrity UK. breaches. When completing the online questionnaire some respondents reported that some of the questions were too broad for them to answer and were therefore left unanswered, meaning the depth of

74 75 References

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76 77 Appendices

Kotter, J. (1995). Leading change: Why Schmidt, M., and Borden, S. (2015, 27 May). ‘In a Appendix 1 – Interview Topic Guide 6. How can you better work together? transformation efforts fail. Harvard Business Review, five-star setting, FIFA officials are arrested, the Swiss a. Think of those present around the table today. 73(2), 59-67. way,’. New York Times. Retrieved from https://www. 1. Tell us a bit about your organisation, your b. Who needs to be involved? nytimes.com/2015/05/28/sports/soccer/in-a-five-star- role, and its links to sports integrity c. Are you happy with current arrangements? Lopez Frias, F. J., and McNamee, M.J. (2019) setting-fifa-officials-are-arrested-the-swiss-way.html a. How important is an integrity function to your d. Please share these “Sports, Ethics, and Integrity.” In The Business organisation? and Culture of Sports: Society, Politics, Economy, Serby, T. (2015). The Council of Europe Convention b. Focused 7. What are your aspirations and realistic future Environment. Vol. III. (ed) J. Maguire. Farmington on Manipulation of Sports Competitions: the best c. SI scattered across various departments plans for sports integrity? Hills, MI: Macmillan. bet for the global fight against match-fixing? The d. Broad or narrow scope a. Barriers International Sports Law Journal, 15(1-2), 83-100. e. What drives your integrity function - Crises, b. Cost McNamee, M. J., and Fleming, S. (2007). Ethics good governance, key person, culture, brand c. Good practice examples? What are you doing audits and corporate governance: The case of public Simon, R. L. (1991). Fair Play: Sports, Values, and protection? well? sector sports organisations. Journal of Business Society. 1st ed. Westview Press. Ethics, 73(4), 425-437. 2. How realistic is it to get everyone working to 8. Anything else integrity related you would like Singh, J. B. (2011). Determinants of the effectiveness the same definition of sports integrity? to discuss? McNamee, M. J. (2013) “The integrity of sport: of corporate codes of ethics: An empirical study. a. Personal integrity a. Key things we should know Unregulated gambling, match fixing and corruption.” Journal of Business Ethics, 101, 385–395. b. Organisational Integrity b. Suggestions going forward Sport, Ethics and Philosophy, 7(1), 173-174. c. Competition Integrity Sport Betting Integrity Forum (2019) https://www. d. Can we capture all parts of Sports Integrity under Mitchell, R. K., Agle, B. R., and Wood, D. J. (1997). sbif.uk/home.aspx these headings? Appendix 2 – Online Survey Toward a Theory of Stakeholder Identification and e. One size fits all approach - broad principles and Salience: Defining the Principle of Who and What Spracklen, K., Hylton, K., and Long, J. (2006). deliver differently? 1. What is the name of your organisation? Really Counts. Academy of Management Review, Managing and monitoring equality and diversity in f. What would fit where? 22(4), 853-886. UK sport: An evaluation of the sporting equals racial 2. In your own words, please define the term equality standard and its impact on organisational 3. Should integrity issues be mandatory for “sports integrity”? What does it include and/ Moore Stephens (2018). The state of sports change. Journal of Sport and Social Issues, 30(3), 289- sports organisations? or exclude? governance: Are you leading or lagging? London: 305. a. What are the key mandatory areas? Birkbeck University. b. Tiered approach 3. Does your organisation have an internal UNODC (2016). https://www.unodc.org/documents/ c. Managing audit/compliance/concordance? integrity (or integrity related) function? Pieth, M. (2011). Governing FIFA: Concept Paper corruption/Publications/2016/V1602591- d. Risk analysis and Report. Basel: Basel University. RESOURCE_GUIDE_ON_GOOD_PRACTICES_IN_ IF YES THE_INVESTIGA TION_OF_MA TCH- FIXING.pdf 4. What are the current biggest threats to sports Riordan, J. (2007). Football: Nation, city and the integrity? 4. Who has ultimate oversight of this function? dream. Playing the game for Russia, money and Van Kersbergen, K., and Van Waarden, F. (2004). i.e. CEO, Board power. Soccer and Society, 8, 545-560. ‘Governance’ as a bridge between disciplines. 5. Investigating threats to integrity? European journal of political research, 43 (2), a. Functions and mechanisms 5. What is the annual budget attached to this Roan, D. (2017, March 10). Jess Varnish: ‘I was 143–171. b. Committees with power to sanction function? thrown under the bus by British Cycling’. BBC c. Codes of ethics? Sport. Retrieved from https://www.bbc.com/sport/ World Anti-Doping Agency. (2019). 2015 World Anti- d. Good practice? 6. Is it connected with any other national or cycling/39234548 Doping Code: June 2019 Ammendments. Retrieved e. Whistleblowing - good or bad? international organisations working on 7th August, 2019, from https://www.wada-ama.org/ integrity issues? If yes, please list en/resources/the-code/2015-world-anti-doping- code-june-2019-amendments

78 79 7. Is there a named individual who is FOR ALL responsible for that function(s)? Please name them if not you 27. In your organisation is there a clear separation between work on sport betting 8. What is your/are their job title(s)? integrity (i.e. event manipulation/match fixing) and other non-betting issues? 9. Do they/you have a job description? If so, please attach 28. Is your organisation a member of the Sports Betting Integrity Forum (SBIF)? 10. To whom are you/they accountable? (please identify role, not individual name) 29. Does your organisation include integrity considerations as part of its risk assessment? 11. How many years’ experience do you/they If so, please attach have in the role? 30. Does your organisation have any 12. What background do you/they have? external integrity functions i.e. outsource whistleblowing reporting lines? 13. What is your/their highest educational qualification? 31. Does your organisation provide any of the following services? 14. Are you/they full-time/part-time? a) Welfare support to members 15. How many, other than that person, are in the b) Independent whistleblowing/reporting line unit responsible for integrity matters? 32. If so, who is it delivered by (internal/ IF ADDITIONAL REPEAT QUESTIONS 8-14 external), and what annual budget is attached to it? IF NO FROM QUESTION 3 33. Does your organisation have a Code of 23. Why do you not have an integrity function? Ethics/Conduct? If so, please attach.

24. Do you have plans to establish an integrity 34. Does your organisation regularly liaise with function? law enforcement or other sport/professional regulators? Please list 25. What have been the barriers to establishing an integrity function? 35. Does your organisation have any information sharing agreements in relation to integrity 26. Who/what do you see playing a role in an issues? integrity function? 36. If you would like us to share the results of this survey with you, please provide your contact details below

80 81 Notes

UK Anti-Doping Fleetbank House 2-6 Salisbury Square London EC4Y 8AE

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82 83 www.ukad.org.uk @ukantidoping #cleansport