F.I.F.A. – Players’ Status Committee / Commissione per lo Status dei Calciatori – coach disputes / controversie allenatori (2019-2020) – fifa.com – atto non ufficiale – Decision 15 April 2020

Decision of the Single Judge

of the Players’ Status Committee

passed on 15 April 2020,

by

Johan van Gaalen (South Africa)

Single Judge of the Players’ Status Committee,

on the claim presented by the coach,

Jose Luis Sierra Pando, Chile,

represented by Mr Salvatore Civale

as Claimant

against the club,

Al Ittihad, Saudi Arabia,

represented by Mr Jan Kleiner

as Respondent

regarding an employment-related dispute

between the parties

I. Facts of the case

1. On 30 May 2019, the Chilean coach, Mr José Luis Sierra (hereinafter: the Claimant) and the Saudi club, Al Ittihad, concluded an employment contract (hereinafter: the contract) valid “for the sporting season 2019/2020, i.e. from 1 June 2019 to 30 May 2020” and by means of which the Claimant was hired as head coach by the Respondent.

2. According to the contract, the Claimant was entitled to receive from the Respondent the net amount of USD 3,000,000 for the 2019/2020 season.

3. As specified in the contract “this salary compensates the Coach and includes possible salary payments for the staff of the Coach. (..) the salary for the staff of the Coach will be paid out of this overall budget of USD 3,000,000.00 (..) and only the remaining amount will constitute the total salary payable to the Coach”.

4. In accordance with “item 4” point 1 of the contract, the Respondent had to pay to the Claimant the amount of USD 1,000,000 “upon signature of this contract” and the “remaining amount (..) in ten monthly instalments (calculated based on the remaining amount of the salary budget as per on the calculation described above) from August 2019 until May 2020, payable by the end of each month.”

5. In addition, the Respondent had to provide the Claimant with a “total of 4 round-trip Business Class tickets on Santiago de Chile – Jeddah – Santiago de Chile per each person, for the use of the Coach and his family. ”

6. Equally, the Respondent had to “secure insurance for the Coach, his Staff members and relevant families according to standard policy of the [Respondent] for all for the entire term of this Contract.”

7. “Item 6” of the contract (hereinafter: the termination clause) clarified that the parties could terminate their contractual relationship “in case of just cause, in accordance with the relevant FIFA jurisprudence and regulations”. The same provision indicated that the Respondent could “terminate the contract at all times by paying to the Coach [i.e. the Claimant] only 6 months of salary as compensation (calculated in the basis of the monthly instalments as determined in Item 4, no 1 [cfr. Point 3 above]) or the remaining monthly instalments due until the end of the season, whichever is lower.”

8. As further mentioned in item 6 of the contract “the coach expressly agrees that this compensation is fair and appropriate”.

9. By means of a letter dated 15 October 2019, the Claimant put the Respondent in default, requesting the payment of USD 1,200,000, corresponding to the “advance payment due on 30 May 2019” in the amount of USD 1,000,000 plus “the salary of September 2019” amounting to USD 200,000, within 10 days.

10. In the same document, the Claimant pointed out that “in accordance with the long standing and well-established jurisprudence of the FIFA judicial bodies (..) the missing payment of an amount corresponding to 2 (..) monthly salaries represents a just cause of termination of the Contract in favour of the Coach. (…) considering that the amount due to [the Claimant] is much higher than the value of two monthly salary, (..)” the Claimant “will not hesitate to terminate the contract with just cause if the Club [i.e. the Respondent] does not remedy in a timely manner.”

11. On 10 November 2019, the Claimant lodged a claim with FIFA against the Respondent for breach of contract and requested from the latter the payment of the total amount of USD 2,944,778.27 as follows:

- USD 1,200,000, corresponding to the “advance payment” and USD 200,000 for his salary of September 2019;

- USD 1,731,708.27 as compensation, corresponding to his monthly salary between October 2019 and May 2020, plus the sum of USD 131,708.27 as “economic value of 14 (..) business class flights tickets round-trip Saudi Arabia to Chile”;

- SAR 14,098.85 “which equals to USD 3,760” as “refund of the surgery operation’ cost”;

- SAR 34,900 “which equals to USD 9,310 as refund of the flight tickets’ costs”.

12. In addition, the Claimant requested the payment of 5% interests as follows:

- on the amount of USD 1,731,708.27 as from 19 October 2019, i.e. the date of the “unilateral termination of contract” by the Respondent;

- on the amount of USD 1,000,000 as from 30 May 2019;

- on the amount of USD 200,000 as from 30 September 2019;

- on the sum of SAR 14,098.85 and of SAR 34,900 as of 10 November 2019.

13. Finally, the Claimant requested that the Respondent contributes to his legal expenses.

14. The Claimant accused the Respondent of having unilaterally terminated the contract without just cause on 19 October 2019 by announcing its decision in “its official medial channel”.

15. As further alleged by the Claimant, the termination in question had followed a team’s defeat against the club Al-Wahda Mekka and the Respondent had publicly justified the termination of contract with the poor performance of the team.

16. The Claimant added that the Respondent had appointed a new head coach shortly after having dismissed him.

17. The Claimant alleged having written to the Respondent on 20 and 28 October 2019 respectively, requesting the payment of outstanding remuneration and of compensation for having terminated the contract without just cause.

18. From the Claimant’s point of view the termination of contract by the Respondent had occurred without just cause.

19. In this respect, the Claimant pointed out that, in accordance with FIFA’s jurisprudence, the absence of sportive results could not be invoked as reason to terminate a contract and the Respondent had never warned him nor gave him any notice for any violation of his contractual duties.

20. The Claimant additionally pointed out that he would have had just cause to terminate the contract in view of the Respondent’s failure to pay part of his remuneration.

21. As a result, the Claimant deemed being entitled to claim from the Respondent the payment of compensation for breach of contract.

22. In this context, the Claimant referred to the termination clause included in the contract and argued that the provision in question was in contrast with the well-established jurisprudence of FIFA as it had been drafted for the benefit of the Respondent’s only. The Claimant considered the relevant provision as being “out of proportion and totally and unilaterally in favour of the Respondent.”

23. In view of the aforementioned, the Claimant argued that the termination clause was to be considered as null and void and that the compensation payable by the Respondent for having unilaterally terminated the contract without just cause was to be calculated taking into account the remaining value of the contract.

24. From the Claimant’s point of view, the remaining value of the contract corresponded to the remaining 8 monthly salary a USD 200,000 each for the period October 2018 until March 2019, i.e. the total sum of USD 1,600,000, plus the value of 14 round flight tickets business class from Jeddah to Chile for him and his coaching team in the total amount of SAR 439,906, i.e. USD 131,708. 27.

25. The Claimant clarified having calculated the amount due as flight tickets on the basis of the prices applied by the company Emirates. However, the Claimant suggested FIFA to refer the question of the quotation of the business class round-trip flight tickets to FIFA Travel Office in case it found it more appropriate.

26. In light of the above, the Claimant calculated the residual value of the contract in the amount of USD 1,731,708.27.

27. As to the outstanding remuneration requested, the Claimant referred to the contract and recalled that the Respondent had to pay him USD 1,000,000 as advance payment and USD 2,000,000 in ten monthly instalments but that he had so far only received the sum of USD 200,000 in August 2018.

28. As a result, the Claimant deemed being entitled to claim the outstanding amount of USD 1,200,000, corresponding the advance payment, i.e. USD 1,000,000, plus the salary of September 2018, i.e. the sum of USD 200,000.

29. In continuation, the Claimant deemed being entitled to request the reimbursement of the amount of SAR 14,098.85, “which equals to USD 3,760”, for a surgery that he had to pay himself as the Respondent had failed to provide him with an insurance despite having contractually been obliged to do so. In this context, the Claimant provided FIFA with an invoice issued on 22 October 2019 in relation to his stay at the Dr Samir Abbas Hospital between 21 and 22 October 2019.

30. Furthermore, the Claimant maintained being entitled to claim from the Respondent the reimbursement of the sum SAR 34,900, “which equals to USD 9,310” corresponding to the price of the flight ticket he had to purchase for him and his coaching team to fly back home after having been dismissed by the Respondent. As to that, the Claimant provided FIFA with an invoice for the amount of SAR 34,900 for four flight tickets for journeys which took places between 22 and 23 October 2019 departing from Jeddah.

31. In its response on 23 January 2020, the Respondent rejected the claim of the Claimant in its entirety.

32. In this respect and to begin with, the Respondent argued that, in the 2019 summer, after having implemented a significant reorganisation in its sporting personnel and relevant changes in its management, it had faced a “temporary liquidity shortage”.

33. In addition, the Respondent clarified having been aware “that the situation was not ideal” and that it “appreciated the cooperation and patience of the Claimant, who never communicated any discontent towards the financial situation vis-à-vis to Respondent.”

34. The Respondent further maintained that, “during a subsequent difficult sporting situation”, on 19 October 2019, its management had decided to make use of the termination clause and terminate the contract.

35. In this context, the Respondent clarified that “unfortunately, there were problems in the communication with the Claimant” and “the issue of fair compensation could (..) not be discussed and therefore also not resolved before the present Claim was lodged.”

36. In continuation, the Respondent argued the validity of the termination clause pointing out that it had been expressly accepted by the Claimant. From the Respondent’s point of view the fact that the Claimant was now challenging the validity of the clause in question was to be considered a “blatant case of “venire contract factum proprium”.”

37. Equally, the Respondent considered “difficult to understand how” the Claimant could view a clause which “ensures compensation of no less than an extra payment of USD 1,200,000” as disproportionate or not acceptable.

38. The Respondent referred to CAS jurisprudence pointing out that “clauses or liquidated damages clauses (…) do not have to be reciprocal” and that as per “DRC and CAS case-law, the only test for the validity of a termination clause is whether it grants disproportionate rights to one party in comparison to the other.”

39. Finally, from the Respondent’s point of view, the termination clause did not endanger the Claimant’s economic existence.

40. In conclusion, the Respondent was of the opinion that the compensation payable to the Claimant was to be calculated in accordance with the termination clause.

41. Hence, the Respondent argued that the maximum amount that the Claimant could request as compensation for termination of contract amounted to USD 1,200,000, “in addition to the amounts that have remained overdue at the moment of the termination”.

42. Subsequently, the Respondent rejected the claim of the Claimant with regard of the flight tickets “which were never bought or bought after the termination of contract” stressing that “granting such requests would clearly breach the Swiss and international law established principle of prohibited enrichment”.

43. Similarly, the Respondent rejected the claim of the Claimant related to reimbursement of the costs of a surgery. The Claimant clarified that the Claimant and his staff members as well as their family “were all covered – among other insurances – by the health insurance of Respondent for the whole duration of the contract. However this does not mean that Claimant can send an invoice for an operation to Respondent. This is not how insurance works.”

44. The Respondent added that the “concerned medical treatment has been requested and performed after the termination of the contractual relationship” and pointed out that “even if the concerned medical costs were covered by the applicable insurance policy, the request for reimbursement should be made to the competent insurance company and not the Respondent.”

45. Finally, the Respondent deemed that the Claimant had a duty to mitigate the dame incurred as the parties had not excluded from the contract such an obligation.

46. As a result and considering that the Claimant had not provided evidence indicating that he had made “diligent and serious efforts to find a new employment”, the Respondent deemed that a “reduction of 50% to the Claimant’s claim would be appropriate to reflect this failure.”

47. In conclusion, the Respondent requested for an “appropriate compensation” to be “established by FIFA, taking into account the contractually defined compensation for termination of contract and Claimant’s clear failure to mitigate his damage.”

48. Asked about his labour situation as of the alleged breach of contract, the Claimant informed FIFA on 23 March 2020 that he had not signed any other employment contract “despite his efforts to look for another job.”

II. Considerations of the Single Judge of the Players’ Status Committee

1. First of all, the Single Judge of the Players’ Status Committee (hereinafter: the Single Judge) analysed whether he was competent to deal with the present matter. In this respect, he took note that the matter was submitted to FIFA on 10 November 2019. Consequently, the 2019 edition of the Rules Governing the Procedures of the Players’ Status Committee and the Dispute Resolution Chamber (hereinafter: the Procedural Rules) is applicable to the matter in hand (cf. art. 21 par. 2 and 3 of the Procedural Rules).

2. Subsequently, the Single Judge referred to art. 3 of the Procedural Rules and confirmed that in accordance with art. 23 par. 1 and 3 in combination with art. 22 lit. c) of the 2020 edition of the Regulations on the Status and Transfer of Players, he is competent to deal with the matter at sake which concerns an employment-related dispute of an international dimension between a Chilean coach and a Saudi club.

3. Furthermore, the Single Judge analysed which edition of the Regulations on the Status and Transfer of Players should be applicable as to the substance of the matter. In this respect, he confirmed that in accordance to art. 26 par. 1 and 2 of the 2020 edition of the Regulations on the Status and Transfer of Players and considering that the present claim was lodged with FIFA on 10 November 2019, the October 2019 edition of the Regulations on the Status and Transfer of Players (hereinafter: the Regulations) is applicable to the present matter as to the substance.

4. His competence and the applicable regulations having been established, and entering into the substance of the matter, the Single Judge started by acknowledging the above-mentioned facts as well as the arguments and the documentation submitted by the parties. However, the Single Judge emphasised that in the following considerations it will refer only to the facts, arguments and documentary evidence, which it considered pertinent for the assessment of the matter at hand.

5. The Single Judge started by acknowledging that on 30 May 2019, the parties had signed a contract valid “for the sporting season 2019/2020, i.e. from 1 June 2019 to 30 May 2020” by means of which the Claimant entitled to receive from the Respondent the total amount of USD 3,000,000 as well as a “total of 4 round-trip Business Class tickets on Santiago de Chile – Jeddah – Santiago de Chile per each person, for the use of the Coach and his family. ”

6. Equally, the Single Judge remarked that the Respondent had to “secure insurance for the Coach, his Staff members and relevant families according to standard policy of the [Respondent] for all for the entire term of this Contract.”

7. In addition, the Single Judge took note of the fact that a termination clause was included in the contract in accordance with which the Respondent could “terminate the contract at all times by paying to the Coach only 6 months of salary as compensation (calculated in the basis of the monthly instalments as determined in Item 4, no 1 [cf. Point 3 above]) or the remaining monthly instalments due until the end of the season, whichever is lower.”

8. In continuation, the Single Judge noticed that, in his claim to FIFA, the Claimant had accused the Respondent of having terminated their contractual relationship without just cause on 19 October 2019 and of having overdue payable towards him. The Single Judge also noted that, because of the aforementioned, the Claimant deemed being entitled to claim from the Respondent outstanding remuneration as well as compensation for breach of contract.

9. Finally, the Single Judge observed that the Respondent for its part, although not contesting that it had not had just cause to terminate the contract, had partially rejected the claim of the Claimant as it did not agreed with the amount of compensation claimed by the latter nor with the total sum requested by the latter as outstanding remuneration.

10. In view of the aforementioned and considering that the Respondent had not contested having overdue payables towards the Claimant nor seemed to challenge the allegation of the latter that the contract had been terminated without just cause and taking into account that the disagreement between the parties concerned only the amount due by the Respondent to the Claimant as outstanding remuneration and compensation for breach of contract, the Single Judge decided to start his analysis of the dispute by first addressing the claim for outstanding remuneration of the Claimant against the Respondent.

11. In this regard, the Single Judge underlined that the Claimant had requested from the Respondent the payment of the amount of USD 1,200,000, corresponding to the advance payment in the amount of USD 1,000,000, plus his salary of September 2019, i.e. the sum of USD 200,000, as well as 5% interests p.a. on the amount of USD 1,000,000 as of 30 May 2019 and on the sum of USD 200,000 as of 30 September 2019.

12. Besides, the Single Judge recalled that the Respondent had not contested having failed to pay to the Claimant the claimed amount.

13. In view of the aforementioned, considering the request of the Claimant as well as the content of the contract with regard to the latter’s remuneration and taking into account the legal principle of pacta sunt servanda, which in essence means that agreements must be respected by the parties in good faith, the Single Judge resolved that the Respondent, in order to fulfil its obligations established in the contract has to pay to the Respondent the outstanding amount of USD 1,200,000.

14. Additionally and with regard to the Claimant’s request for interest, the Single Judge, in accordance with his well-established jurisprudence, decided that the Respondent has to pay to the Claimant 5% interests as of the day after the respective due date of the amounts due as follows: 5% interests p.a. over the amount of USD 1,000,000 as of 31 March 2019 until the date of effective payment and 5% p.a. over the amount of USD 200,000 from 1 October 2019.

15. Having established the aforementioned, the Single Judge turned his attention to the request of the Claimant related to the payment USD 131,708.27 as “economic value of 14 (…) business class flights tickets round-trip Saudi Arabia to Chile” and to the reimbursement of the amount of SAR 34,900, corresponding to the flight tickets purchased for himself and his coaching team to fly back home after having been dismissed by the Respondent.

16. In this context and to begin with, the Single Judge pointed out that the contract did not include a specific amount to be paid to the Claimant as flight tickets and that the flight tickets were due to the coach and his team in order for them to fly back home during the validity of the contract.

17. In view of the above and considering that the contract was terminated prematurely, the Single Judge, in accordance with his well-established jurisprudence, decided that the claim of the Claimant related to the payment of USD 131,708.28 as value for 14 business flights tickets was to be rejected.

18. Nevertheless and with regard to the request made by the Claimant to be reimbursed for the flight tickets purchased to fly back home after the termination of contract by the Respondent, the Single Judge pointed out that the contract did include a provision related to the obligation of the Respondent to provide the Claimant with a certain amount of flight tickets and that the Claimant had provided evidence in support of the allegation that he had spent the sum of SAR 34,900 for the relevant flight tickets.

19. Taking into account the aforementioned and in accordance with his well-established jurisprudence, the Single Judge well-established that the Respondent had to pay to the Claimant the amount of SAR 34,900, corresponding to the amount paid for the flight tickets for him and his team to go back home after the termination of contract.

20. Subsequently and as to the Claimant’s request related to the payment of interests on the aforementioned amount, the Single Judge, in accordance with his well-established jurisprudence decided that the Respondent has to pay 5 interests p.a. on the sum of SAR 34,900 as from 10 November 2019, i.e. as from the day on which the Claimant lodged his claim with FIFA.

21. Having established the aforementioned and turning his attention to the compensation payable to the Claimant by the Respondent following the termination without just cause of contract by the latter, the Single Judge reverted to the content of the termination clause included in the contract and pointed out that the relevant provision only concerned a possible termination of contract by the Respondent and did not regulate the eventuality of a termination of contract by the Claimant. Furthermore, the Single Judge noted that such clause allowed the Respondent to terminate the contract at any time, by paying to the Claimant “6 months of salary as compensation (...) or the remaining monthly instalments due until the end of the season, whichever is lower.”. As a result, the Single Judge deemed that the clause in question was not reciprocal. Thus, the Single Judge concluded that such clause could not be applied and that the amount of compensation due to the Claimant had to be assessed in accordance with other criteria.

22. Equally, the Single Judge observed that since having been dismissed by the Respondent, the Claimant had remained unemployed.

23. Considering all of the aforementioned and, in particular, bearing in mind the unjustified termination of contract by the Respondent, as well as taking into account the specific request of the Claimant, the Single Judge, in accordance with his well-established jurisprudence, concluded that it was fair and reasonable that the Respondent paid to the Claimant the remaining value of the contract. Hence, the Single Judge calculated that in casu the amount of USD 1,600,000, corresponding to his monthly salary between October 2019 and the end of May 2020, i.e. 8 times USD 200,000, constituted a reasonable and justified amount of compensation for breach of contract. In view of the above, the Single Judge concluded that the amount of USD 1,600,000 should be paid by the Respondent to the Claimant.

24. In addition and with regard to the Claimant’s request for interest, the Single Judge, in accordance with his well-established jurisprudence, decided that the Respondent has to pay to the Claimant 5% interest p.a. on the amount of USD 1,600,000 as from 10 November 2019, i.e. the date of the Claimant’s claim, until the date of effective payment.

25. Subsequently, the Single Judge took into account the claim of the Claimant in relation to the reimbursement of the costs incurred in connection with a surgery that was performed between 22 and 23 October 2019, i.e. after the contract had already been terminated. As a result, the Single Judge was of the opinion that the costs for the surgery in question were not to be paid by the Respondent and decided to reject the claim of the Claimant related to the reimbursement of the amount of SAR 14,098.85.

26. Finally, the Single Judge decided to reject the Claimant’s claim pertaining to legal costs in accordance with art. 18 par. 4 of the Procedural Rules and the Chamber’s respective longstanding jurisprudence in this regard.

27. In addition, the Single Judge established that any other request of the Claimant had to be rejected.

28. Lastly, the Single Judge referred to art. 25 par. 2 of the Regulations in combination with art. 18 par. 1 of the Procedural Rules, according to which in the proceedings before the Players’ Status Committee and the Single Judge, costs in the maximum amount of CHF 25,000 are levied. The costs are to be borne in consideration of the parties’ degree of success in the proceedings and are normally to be paid by the unsuccessful party.

29. In this respect, the Single Judge reiterated that the Claimant’s claim is partially accepted, whereas the Respondent is still at fault. Therefore, the Single Judge decided that both parties shall bear the costs of the current proceedings in front of FIFA.

30. Furthermore and according to Annexe A of the Procedural Rules, the costs of the proceedings are to be levied on the basis of the amount in dispute. Consequently and taking into account that the amount at dispute in the present matter, the Single Judge concluded that the maximum amount of costs of the proceedings corresponds to CHF 25,000.

31. In conclusion and in view of the low level of complexity of the present matter from a legal and factual point of view, the Single Judge determined the costs of the current proceedings to the amount of CHF 25,000.

32. Consequently, the Single Judge determined that the Claimant has to pay CHF 5,000 and the Respondent has to pay the amount of CHF 20,000 in order to cover the costs of the present proceedings.

III. Decision of the Single Judge of the Players’ Status Committee

1. The claim of the Claimant, Jose Luis Sierra Pando, is partially accepted.

2. The Respondent, Al Ittihad, has to pay to the Claimant within 30 days as from the date of notification of this decision, outstanding remuneration in the amount of USD 1,200,000 and SAR 34,900, plus interest until the date of effective payment as follows:

a. 5% interest p.a. on the amount of USD 1,000,000 as from 31 May 2019;

b. 5% interest p.a. on the amount of USD 200,000 from 1 October 2019;

c. 5% interest p.a. on the amount of SAR 34,900 as from 10 November 2019.

3. The Respondent has to pay to the Claimant within 30 days as from the date of notification of this decision, compensation for breach of contract in the amount of USD 1,600,000, plus interest of 5% p.a. as of 10 November 2019 until the date of effective payment.

4. The Claimant is directed to inform the Respondent immediately and directly of the account number to which the remittance is to be made and to notify the Single Judge of the Players’ Status Committee of every payment received.

5. If the aforementioned sums plus interest as established above, are not paid within the aforementioned deadline, the present matter shall be submitted, upon request, to the FIFA Disciplinary Committee for consideration and a formal decision.

6. The final costs of the proceedings in the amount of CHF 25’000 are to be paid by both parties as follows:

6.1. The amount of CHF 5,000 has to be paid by the Claimant. Considering that the latter already paid an advance of costs in the amount of CHF 5,000 at the start of the present proceedings, the Claimant is exempted from paying the aforementioned procedural costs.

6.2. The amount of CHF 20,000 has to be paid by the Respondent to FIFA to the following bank account with reference to case nr. 19-02127:

UBS Zurich

Account number 366.677.01U (FIFA Players’ Status)

Clearing number 230

IBAN: CH27 0023 0230 3666 7701U

SWIFT: UBSWCHZH80A

7. Any further claim lodged by the Claimant is rejected.

Note related to the publication:

The FIFA administration may publish decisions issued by the Players’ Status Committee or the DRC. Where such decisions contain confidential information, FIFA may decide, at the request of a party within five days of the notification of the motivated decision, to publish an anonymised or a redacted version (cf. article 20 of the Rules Governing the Procedures of the Players’ Status Committee and the Dispute Resolution Chamber).

Note related to the appeal procedure:

According to article 58 par. 1 of the FIFA Statutes, this decision may be appealed against before the Court of Arbitration for Sport (CAS). The statement of appeal must be sent to the CAS directly within 21 days of receipt of notification of this decision and shall contain all the elements in accordance with point 2 of the directives issued by the CAS. Within another 10 days following the expiry of the time limit for filing the statement of appeal, the appellant shall file a brief stating the facts and legal arguments giving rise to the appeal with the CAS (cf. point 4 of the directives).

The full address and contact numbers of the CAS are the following:

Court of Arbitration for Sport

Avenue de Beaumont 2

1012 Lausanne

Switzerland

Tel: +41 21 613 50 00

Fax: +41 21 613 50 01

e-mail: info@tas-cas.org

For the Single Judge of the

Players’ Status Committee:

___________________

Emilio García Silvero

Chief Legal & Compliance Officer