F.I.F.A. – Dispute Resolution Chamber / Camera di Risoluzione delle Controversie – labour disputes / controversie di lavoro (2019-2020) – fifa.com – atto non ufficiale – Decision 25 February 2020

Decision of the

Dispute Resolution Chamber

passed in Zurich, Switzerland, on 25 February 2020,

in the following composition:

Omar Ongaro (Italy), Chairman

Stéphane Burchkalter (France), member

Jérôme Perlemuter (France), member

on the claim presented by the player,

Ismael Salim Dunga, Kenya,

represented by Ms Athina Adamakou

as Claimant

against the club,

KS Luftetari, Albania

represented by Mr Konstantinos Zemberis

as Respondent

regarding an employment-related dispute between the parties

I. Facts of the case

1. On 30 August 2018, the player, Ismael Salim Dunga (hereinafter: the player or the Claimant) concluded an employment contract (hereinafter: the contract) with the club, KS Luftetari (hereinafter: the club or the Respondent), valid as from 31 August 2018 until 30 June 2021.

2. In accordance with art. 3 of the contract “the Club shall pay to the player for in first four months of the first year of the said contract a monthly salary of one thousand euro net (1000 euro). For the rest of the first season the player will receive a monthly salary of two thousand five hundred euro net (2500) Euro. For the second year of the said contract a monthly salary of three thousand euro net (3000 Euro), and for the third season of the said contract a monthly salary of four thousand euro net (4000 Euro). The monthly salary will be paid at maximum at the 10th day of each month”.

3. In addition, in art. 4 of the contract the parties agreed that “the club will pay all taxes and other obligations toward the authorities concerning all amounts of the said contract”.

4. Moreover, in accordance with art. 8 of the contract “the club will arrange all documents to provide to the player permission of stay and work in Albania.”

5. Finally, art. 18 of the contract stipulated that “in the event of a dispute regarding the execution of the terms of the present contract, the applicable law will be the FSHF regulation and the applicable court will be the court of Albanian Football Association exclusively”.

6. On 6 May 2019, the player put the club in default for the payment of EUR 8,800, corresponding to the unpaid part of the salary for January 2019 in the amount of EUR 1,300 and the full salaries for February, March and April 2019 in the amount of EUR 2,500 each, setting a deadline of 10 days.

7. On 25 May 2019, the player unilaterally terminated the contract invoking the club’s non-compliance with its financial obligations.

8. On 27 May 2019, Claimant lodged a claim for breach of contract and requested the payment of the following amounts:

Outstanding remuneration: EUR 11,300, plus 5% interest p.a. as from the respective due dates, corresponding to the following:

- EUR 1,300, corresponding to the unpaid part for the salary of January 2019;

- EUR 2,500, corresponding to the salary of February 2019;

- EUR 2,500, corresponding to the salary of March 2019;

- EUR 2,500, corresponding to the salary of April 2019;

- EUR 2,500, corresponding to the salary of May 2019.

Compensation: EUR 86,500, “relating to the residual value of the Player’s contract (2500 EUR for season 2018/2019, EUR 36.000 for season 2019/2020 and EUR 48.000 for season 2020/2021), with an interest rate of 5% p.a. as of May 24th, 2019.”

9. The Claimant further requested the imposition of sporting sanctions against the Respondent.

Competence of FIFA and admissibility of the claim

10. In its reply, the club rejected FIFA’s competence based on the jurisdiction clause in art. 18 of the contract.

11. In this regard, the club deemed that “since the parties in the present case have explicitly agreed that any disputes shall be submitted exclusively to the Albanian NDRC, FIFA does not have jurisdiction to deal with the present matter”.

12. According to the club, “the Albanian NDRC is in fact an independent deciding body that guarantees fair proceedings and respects the principle of equal representation of players and clubs.”

13. In support of its position, the club presented a copy of the Articles of Association of Federata Shqiptare e Futbollit and the Regulations of AFA’s National Dispute Resolution Chamber, which include, inter alia, the following:

“Article 4 - Composition of the Chamber

1. NDRC members shall serve a four-year mandate. Chamber Members shall be entitled to re-election for a second mandate.

2. The Chamber shall be composed of:

a) The Chairman and two deputy Chairmen unilaterally elected by the members of the dispute resolution chamber, based on the proposals of the clubs and player’s assembly for the Chairman and the Deputy Chairmen;

b) Five members, player representatives elected from a voting session organised by AFA, with the participation of two players for each professional team, one of which should be the captain of the team and the other one should be the oldest player. Player representatives also review coaches’ disputes.

c) Five members, club representatives which are elected or appointed on the proposal of the clubs of the Albanian Superliga, First Division and Second Division.

3. The Chairman and the two deputy Chairmen, and the player and club representative members, shall be lawyers with a complete university education, qualified and if possible according to the following specifications:

a) Professor at university;

b) Magistrate;

c) Judge with five-year experience.

All candidates must have high reputation, they must not have been criminally convicted and they must present references from personalities, scholars, former HCJ chairman, etc.”

“Article 8 - Official language of the Chamber

1. The proceedings shall be held in the Albanian language.

2. The chamber may hire a translator during the proceedings, depending on the respective situation.

3. If Albanian is not the mother tongue of one of the parties involved in the judgement, then the Chamber must issue a translated version of the corresponding decision. In the case of any ambiguity, the decision in Albanian language prevails over the decision in foreign languages.”

“Article 33 - Procedural costs

Application costs in the National Dispute Resolution Chamber are 100,000 (one hundred thousand) ALL. They cannot incur additional costs, except for the cases provided for in Article 21 paragraph 5. Expenses at the end of the trial are charged to the losing party.”

Positions of the parties

14. In his claim, the player deemed that the club “failed to comply in full with its obligations deriving from the contract, owning to the Claimant significant amounts from his revenues”.

15. Furthermore, the player argued that despite his formal written default notice, the club never replied or paid he was “facing serious financial problems and had a great difficulty living in a foreign country”.

16. In addition, the player highlighted that “the Respondent has not done anything so far to secure and provide him with the permit of Stay as well as work permit thus breaching the terms of the Contract (Clause 8) making his living and working in Albania illegal and setting the Claimant in a state of permanent danger of being arrested and deported”.

17. In its reply, the club rejected the player’s claim.

18. In particular, the club deemed that “the Claimant and his agent Mr. Kostakis, in bad faith, were reassuring KS Luftetari in all their communications and meetings with the club that the Claimant just wanted to receive the outstanding amounts but he had no intention to terminate his contract”.

19. In this regard, the club referred to the player’s default notice, where the player mentioned art. 12bis of the RSTP and not art. 14bis.

20. Furthermore, the club stressed that the player “had actually agreed with KS Luftetari to sign an agreement providing for a payment plan for the amounts due and he deliberately used excuses to delay the execution of such agreement, obviously with the aim to allow enough time to pass so that he terminates his contract on 25 May 2019”.

21. Consequently, the club argued that “the claim of the Claimant should not be accepted and should be rejected on the basis that his termination was abusive, without just cause and made in bad faith”.

22. On 1 July 2019, the player signed an employment contract with the Albanian club, FC Tirana, valid as from 1 August 2019 until 31 May 2020, according to which the player was entitled to a sign-on fee in the amount of EUR 5,000 and a monthly salary in the amount of EUR 2,500

II. Considerations of the Dispute Resolution Chamber

1. First of all, the Dispute Resolution Chamber (hereinafter: the DRC or the Chamber) analysed whether it was competent to deal with the case at hand. In this respect, it took note that the present matter was submitted to FIFA on 27 May 2019 and decided on 25 February 2020. 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 at hand (cf. art. 21 of the Procedural Rules).

2. Subsequently, the members of the Chamber referred to art. 3 par. 1 of the Procedural Rules and confirmed that in accordance with art. 24 par. 1 in combination with art. 22 lit. b) of the Regulations on the Status and Transfer of Players (January 2020 edition), the Dispute Resolution Chamber would, in principle, be competent to deal with the matter at stake, which concerns an employment-related dispute with an international dimension between a Kenyan player and an Albanian club.

3. However, the DRC acknowledged that the Respondent contested the competence of FIFA’s deciding bodies on the basis of art. 18 of the contract highlighting that the Albanian Football Association has an independent deciding body to deal with the matter, i.e. the National Dispute Resolution Chamber of the Albanian Football Association (hereinafter: Albanian NDRC).

4. Taking into account all the above, the Chamber emphasised that in accordance with art. 22 lit b) of the Regulations on the Status and Transfer of Players, it is, in principle, competent to deal with employment-related disputes of an international dimension; the parties may, however, explicitly opt in writing for any disputes arisen between them to be decided by an independent arbitration tribunal guaranteeing fair proceedings and respecting the principle of equal representation of players and clubs that has been established at national level within the framework of the association and/or a collective bargaining agreement. Any such arbitration clause must be included either directly in the contract or in a collective bargaining agreement applicable on the parties. With regard to the standards to be imposed on an independent arbitration tribunal existing at national level, the DRC referred to the FIFA Circular no. 1010 dated 20 December 2005. Equally, the members of the DRC referred to the principles contained in the FIFA National Dispute Resolution Chamber (NDRC) Standard Regulations, which came into force on 1 January 2008.

5. With the aforementioned in mind, the Chamber first pointed out that, in the present matter, indeed it would appear that the parties agreed, by means of art. 18 the contract, that the disputes arisen between them in relation to the employment contract would be resolved by the Albanian NDRC.

6. Nevertheless, and in accordance with said art. 22 lit. b) of the Regulations, the DRC emphasised that it needed to analyse whether the entire dispute resolution system within the Albanian Football Association, actually complies with the requirements as mentioned in point II./4. above. In so doing, the DRC recalled that, in accordance with art. 12 par. 3 of the Regulations, it is for the Respondent to prove that the Albanian NDRC is an independent tribunal guaranteeing fair proceedings and which respects the principle of equal representation of players and clubs.

7. The Chamber further stressed that the principle of equal representation of players and clubs is one of the very fundamental elements to be fulfilled, in order for a national dispute resolution chamber to be recognised as such. Indeed, this prerequisite is mentioned in the Regulations, in the FIFA Circular no. 1010 as well as in art. 3 par. 1 of the NDRC Regulations, which illustrates the aforementioned principle as follows: “The NDRC shall be composed of the following members, who shall serve a four-year renewable mandate: a) a chairman and a deputy chairman chosen by consensus by the player and club representatives (…); b) between three and ten player representatives who are elected or appointed either on proposal of the players’ associations affiliated to FIFPro, or, where no such associations exist, on the basis of a selection process agreed by FIFA and FIFPro; c) between three and ten club representatives (…).” In the same vein, the FIFA Circular no. 1010 states the following: “The parties must have equal influence over the appointment of arbitrators. This means for example that every party shall have the right to appoint an arbitrator and the two appointed arbitrators appoint the chairman of the arbitration tribunal (…). Where arbitrators are to be selected from a predetermined list, every interest group that is represented must be able to exercise equal influence over the compilation of the arbitrator list”.

8. Taking into account the above, the members of the DRC entered into the examination of the Albanian NDRC Regulations, which were submitted by the Respondent during the course of the investigation of the matter at stake.

9. In particular, the DRC judge observed in accordance with article 4 par. 2. lit. b of the Albanian NDRC Regulations, the 5 members as player representatives are elected “from a voting session organised by AFA, with the participation of two players from each professional team, one which should be the captain of the team and the other one should be the oldest player”.

10. In this respect, the DRC noted that, from the above mentioned article of the Albanian NDRC Regulations, the principle of equal representation of players and clubs is not respected with regard to the appointment of the 5 members as player representatives, as the election of these members can be heavily influenced by the Albanian Football Association, which is organising the voting session.

11. In view of all the above, the DRC established that the Respondent’s objection to the competence of FIFA to deal with the present matter has to be rejected and that the DRC is competent, on the basis of art. 22 lit. b) of the Regulations on the Status and Transfer of Players, to consider the present matter as to the substance.

12. Subsequently, the Chamber analysed which regulations should be applicable as to the substance of the matter. In this respect, the Chamber confirmed that in accordance with art. 26 par. 1 and 2 of the Regulations on the Status and Transfer of Players (January 2020 edition), and considering that the claim was lodged on 27 May 2019, the June 2018 edition of the aforementioned regulations (hereinafter: the Regulations) is applicable to the matter at hand as to the substance.

13. The competence of the Chamber and the applicable regulations having been established, the Chamber entered into the substance of the matter. In this respect, the Chamber started by acknowledging all the above-mentioned facts as well as the arguments and the documentation submitted by the parties. However, the Chamber 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. In particular, the Chamber recalled that, in accordance with art. 6 par. 3 of Annex 3 of the Regulations, FIFA may use, within the scope of proceedings pertaining to the application of the Regulations, any documentation or evidence generated or contained in the TMS.

14. Having said this, the Chamber proceeded with an analysis of the circumstances surrounding the present matter, the parties’ arguments as well the documentation on file.

15. First of all, the members of the Chamber acknowledged that, on 30 August 2018, the player and the club had concluded an employment contract valid as from 31 August 2018 until 30 June 2021, pursuant to which the club undertook to pay to the player the remuneration, as established in point I.2 above.

16. Furthermore, the members of the DRC took note of the fact that, on 6 May 2019, the player had put the club in default of payment of the amount of 8,800, corresponding to the unpaid part of the salary for January 2019 in the amount of EUR 1,300 and the full salaries for February, March and April 2019 in the amount of EUR 2,500 each, setting a deadline of 10 days in order to remedy the default.

17. Moreover, the DRC took note that, according to the player, he had just cause to unilaterally terminate the employment contract on 25 May 2019, since the club failed to reply to his default notice sent on 6 May 2019 and since no payment had been made by the latter in this respect. In this regard, the player affirmed that he had no alternative but to terminate the contract and deemed that the club should be held liable for the early termination of said contract.

18. In continuation, the Chamber observed that the club claimed that the player terminated the contract without just cause.

19. Moreover, the DRC noted that the club argued that instead of referring to art. 14bis of the Regulation in the default notice, the player referred to art. 12bis of the Regulation, which according to the club was a clear indication that “the Claimant just wanted to receive the outstanding amounts but he had no intention to terminate his contract”. The Chamber further observed that the club stressed that the player “actually agreed with KS Luftetari to sign an agreement providing for a payment plan for the due amounts”.

20. In light of the foregoing, the DRC considered that the underlying issue in this dispute, considering the parties’ position, was to determine as to whether the player had just cause to terminate the employment contract and to determine the consequences thereof.

21. In this context, the Chamber deemed it appropriate to refer to art. 12 par. 3 of the Procedural Rules, according to which any party claiming a right on the basis of an alleged fact shall carry the respective burden of proof. The application of the principle in the present matter led the Chamber to conclude that the player bore the burden of proving his allegations regarding the work permit. However, in regards to the outstanding payment, the Chamber pointed out that the Respondent bore the burden of proving either the payment of the Claimant’s salaries or that it had a valid reason for not having done so.

22. Having said that, the Chamber observed that the player did not provide any further information or any evidence for his allegations that the club did not arrange a “stay as well as work permit” and therefore, the Chamber concluded that it could not take these allegations into consideration.

23. Furthermore, and concerning the club’s allegations that the parties agreed to conclude an “agreement providing for a payment plan”, the Chamber observed that the club did not provide any evidence for its arguments.

24. With the above in mind, the Chamber highlighted that on the basis of the parties’ submissions, it could be noted that the club did not contest that, by the time the player addressed it with his default letter on 6 May 2019, more than 3 monthly salaries remained unpaid. Moreover the members of the DRC observed that it also remained undisputed that the player provided the club with 10 days to remedy its default and that the club never reacted to the default letter.

25. On account of the above and taking into consideration the Chamber’s longstanding jurisprudence in this respect, the Chamber decided that the Claimant had just cause to unilaterally terminate the contract on 25 May 2019 and that the Respondent is to be held liable for the early termination of the contract with just cause by the player.

26. Having established that the club is to be held liable for the early termination of the employment contract, the DRC focused its attention on the consequences of such termination. Taking into consideration art. 17 par. 1 of the Regulations, the DRC established that the player is entitled to receive from the club compensation for breach of contract, in addition to any outstanding payments on the basis of the relevant employment contract.

27. Along those lines, the DRC firstly referred to the player’s request regarding the outstanding remuneration at the time of the unilateral termination of the employment contract. In this respect, the DRC concurred that the club must fulfil its obligations as per the employment contract in accordance with the general legal principle of “pacta sunt servanda”.

28. Consequently, and bearing in mind that the player terminated his employment contract on 25 May 2019, the Chamber decided that the club is liable to pay to the player outstanding remuneration in the amount of EUR 11,300, corresponding to the player’s salaries for the months of February until May 2019..

29. In addition, taking into account the player’s request and the DRC’s well-established jurisprudence, the Chamber decided that the club must pay to the player 5% interest p.a. until the date of effective payment as follows:

a. on the amount of EUR 1,300, as from 1 February 2019;

b. on the amount of EUR 2,500, as from 1 March 2019;

c. on the amount of EUR 2,500, as from 1 April 2019;

d. on the amount of EUR 2,500, as from 1 May 2019;

e. on the amount of EUR 2,500, as from 1 June 2019.

30. Moreover, and taking into consideration art. 17 par. 1 of the Regulations, the Chamber decided that the player is entitled to receive compensation for breach of contract from the club.

31. In continuation, the DRC focused his attention on the calculation of the amount of compensation for breach of contract due to the Claimant by the Respondent in the case at stake. In doing so, the DRC firstly recapitulated that, in accordance with art. 17 par. 1 of the Regulations, the amount of compensation shall be calculated, in particular and unless otherwise provided for in the contract at the basis of the dispute, with due consideration for the law of the country concerned, the specificity of sport and further objective criteria, including, in particular, the remuneration and other benefits due to the player under the existing contract and/or the new contract, the time remaining on the existing contract up to a maximum of five years, and depending on whether the contractual breach falls within the protected period.

32. In application of the relevant provision, the Chamber held that it first of all had to clarify whether the pertinent employment contract contained any clause, by means of which the parties had beforehand agreed upon a compensation payable by the contractual parties in the event of breach of contract. In this regard, the Chamber observed that the employment contract does not contain any such clause.

33. As a consequence, the members of the Chamber determined that the amount of compensation payable by the club to the player had to be assessed in application of the parameters set out in art. 17 par. 1 of the Regulations. Bearing in mind the foregoing, the Chamber proceeded with the calculation of the monies payable to the player under the terms of the employment contract as from its termination and concluded that the player would have been entitled to receive EUR 86,500 as remuneration had the employment contract been executed until its regular expiry date, i.e. 30 June 2021. Consequently, the Chamber concluded that the amount of EUR 86,500 serves as the basis for the final determination of the amount of compensation for breach of contract in the case at hand.

34. In continuation, the Chamber assessed whether the player had signed an employment contract with another club during the relevant period of time, by means of which he would have been able to reduce his loss of income. In this respect, the DRC deemed it necessary to refer to the first sentence of art. 17 par. 1 lit. ii) of the Regulations, according to which, in case the player signed a new contract by the time of the decision, the value of the new contract for the period corresponding to the time remaining on the prematurely terminated contract shall be deducted from the residual value of the contract that was terminated early (the ”Mitigated Compensation”).

23. In respect of the above, and according to the information provided by the player, the Chamber recalled that, on 1 July 2019, the Claimant signed an employment contract with the Albanian club, FC Tirana, valid as from 1 August 2019 until 31 May 2020 according to which, he was entitled to, inter alia, a sign-on fee in the amount of EUR 5,000 and a monthly salary in the amount of EUR 2,500. On account of the above, such amount shall be deducted, leading to a mitigated compensation in the amount of EUR 56,500.

35. Subsequently, the Chamber turned its attention to the second sentence of art. 17 par. 1 lit. ii) of the Regulations, according to which, in addition to the mitigated compensation, the player shall be entitled to an additional compensation of three monthly salaries, subject to the early termination of the contract being due to overdue payables.

36. Therefore, taking into consideration the player’s monthly salary under the prematurely terminated contract, which the DRC deemed to be EUR 3,029 calculated as an average amount received per month, the Chamber decided to award the Claimant an additional compensation in the amount of EUR 9,087, in accordance with the above-mentioned provision.

37. Consequently, on account of all the above-mentioned considerations, the Chamber decided that the club must pay the amount of EUR 65,587 as compensation for breach of contract to the player, which is considered by the Chamber to be a fair and reasonable amount.

38. In addition, taking into consideration the player’s claim, the Chamber decided to award the player interest at the rate of 5% p.a. as of the date of the claim, i.e. 27 May 2019, until the date of effective payment.

39. Therefore, the DRC decided to partially accept the player’s claim and concluded its deliberations by rejecting any further claim of the player.

40. Furthermore, taking into account the consideration under number II./12. above, the Chamber referred to par. 1 and 2 of art. 24bis of the Regulations, which stipulate that, with its decision, the pertinent FIFA deciding body shall also rule on the consequences deriving from the failure of the concerned party to pay the relevant amounts of outstanding remuneration and/or compensation in due time.

41. In this regard, the Chamber pointed out that, against clubs, the consequence of the failure to pay the relevant amounts in due time shall consist of a ban from registering any new players, either nationally or internationally, up until the due amounts are paid and for the maximum duration of three entire and consecutive registration periods.

42. Therefore, bearing in mind the above, the DRC decided that, in the event that the Respondent does not pay the amounts due to the Claimant within 45 days as from the moment in which the Claimant, following the notification of the present decision, communicates the relevant bank details to the Respondent, a ban from registering any new players, either nationally or internationally, for the maximum duration of three entire and consecutive registration periods shall become effective on the Respondent in accordance with art. 24bis par. 2 and 4 of the Regulations.

43. Finally, the Chamber recalled that the above-mentioned ban will be lifted immediately and prior to its complete serving upon payment of the due amounts, in accordance with art. 24bis par. 3 of the Regulations.

III. Decision of the Dispute Resolution Chamber

1. The claim of the Claimant, Ismael Salim Dunga, is admissible.

2. The claim of the Claimant is partially accepted.

3. The Respondent, KS Luftetari, has to pay to the Claimant the amount of EUR 11,300, plus 5% interest p.a. until the date of effective payment as follows:

a. on the amount of EUR 1,300, as from 1 February 2019;

b. on the amount of EUR 2,500, as from 1 March 2019;

c. on the amount of EUR 2,500, as from 1 April 2019;

d. on the amount of EUR 2,500, as from 1 May 2019;

e. on the amount of EUR 2,500, as from 1 June 2019.

4. The Respondent has to pay to the Claimant compensation for breach of contract in the amount of EUR 65,587, plus 5% interest p.a. as from 27 May 2019 until the date of effective payment.

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

6. The Claimant is directed to inform the Respondent, immediately and directly, preferably to the email address as indicated on the cover letter of the present decision, of the relevant bank account to which the Respondent must pay the amounts plus interest mentioned under points 3. and 4. above.

7. The Respondent shall provide evidence of payment of the due amounts in accordance with points 3. and 4. above to FIFA to the e-mail address psdfifa@fifa.org, duly translated into one of the official FIFA languages (English, French, German, Spanish).

8. In the event that the amounts due in accordance with points 3. and 4. above are not paid by the Respondent within 45 days as from the notification by the Claimant of the relevant bank details to the Respondent, the Respondent shall be banned from registering any new players, either nationally or internationally, up until the due amounts are paid and for the maximum duration of three entire and consecutive registration periods (cf. art. 24bis of the Regulations on the Status and Transfer of Players).

9. The ban mentioned in point 8. above will be lifted immediately and prior to its complete serving, once the due amounts are paid.

10. In the event that the amounts due in accordance with points 3. and 4. above are still not paid by the end of the ban of three entire and consecutive registration periods, the present matter shall be submitted, upon request, to FIFA’s Disciplinary Committee for consideration and a formal decision.

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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 relating to the motivated decision (legal remedy):

According to art. 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 (CAS)

Avenue de Beaumont 2, CH-1012 Lausanne

Switzerland

Tel: +41 21 613 50 00

e-mail: info@tas-cas.org

For the Dispute Resolution Chamber:

Emilio García Silvero

Chief Legal & Compliance Officer