F.I.F.A. – Camera di Risoluzione delle Controversie (2013-2014) – controversie di lavoro – ———- F.I.F.A. – Dispute Resolution Chamber (2013-2014) – labour disputes – official version by www.fifa.com – Decision of the Dispute Resolution Chamber passed in Zurich, Switzerland, on 9 May 2014, in the following composition: Geoff Thompson (England), Chairman Johan van Gaalen (South Africa), member Damir Vrbanovic (Croatia), member on the claim presented by the player, Player F, from country B as Claimant / Counter-Respondent against the club, Club K, from country G as Respondent / Counter-Claimant with the club, Club B, from country P as Intervening Party regarding an employment-related dispute arisen between the parties

F.I.F.A. - Camera di Risoluzione delle Controversie (2013-2014) - controversie di lavoro - ---------- F.I.F.A. - Dispute Resolution Chamber (2013-2014) - labour disputes – official version by www.fifa.com – Decision of the Dispute Resolution Chamber passed in Zurich, Switzerland, on 9 May 2014, in the following composition: Geoff Thompson (England), Chairman Johan van Gaalen (South Africa), member Damir Vrbanovic (Croatia), member on the claim presented by the player, Player F, from country B as Claimant / Counter-Respondent against the club, Club K, from country G as Respondent / Counter-Claimant with the club, Club B, from country P as Intervening Party regarding an employment-related dispute arisen between the parties I. Facts of the case 1. On 15 August 2009, Player F, from country B (hereinafter: player or Claimant/Counter-Respondent), and Club K, from country G (hereinafter: club or Respondent/Counter-Claimant), signed an employment contract made out on the country G super league form valid as from the date of signature until 30 June 2012 (hereinafter: super league contract). 2. In accordance with the super league contract, the club undertook to pay to the player a monthly salary of EUR 826 (12x per year) and Christmas, Easter and holiday bonuses equalling 2 monthly salaries. 3. In addition, the player was to receive the amount of EUR 15,000 in six instalments of EUR 2,500 each, falling due on 30 December 2009, 30 June 2010, 30 December 2010, 30 June 2011, 30 December 2011, and 30 June 2012. 4. According to the super league contract, the regulations of the “professional association”, among others, are an integral part of the contract. 5. The super league contract refers to art. 17 par. 2 of “the Regulations” in connection with compensation for breach of contract in the event of the parties terminating the contract without just cause. 6. Art. 5.6 of the super league contract stipulates that: “The player is entitled to buy the remainder of his contract, by paying out to the Club the amount of 1,000,000 EUR”. 7. On 15 August 2009, the player and the club signed a “private agreement” (hereinafter: agreement), which refers to the signature by the parties of the country G super league contract and which determines that the payments in accordance with the country G super league contract are included in the agreement, which are not to be added together. 8. According to the agreement, the club undertook to pay, inter alia, the following remuneration to the player: • 2010-11 season: Total of EUR 140,000 in 11 monthly payments: EUR 40,000 on 30 August 2010 and 10 x EUR 10,000 as from 30 September 2010 until 30 June 2011. • 2011-12 season: Total of EUR 160,000 in 11 monthly payments: EUR 60,000 on 30 August 2011 and 10 x EUR 10,000 as from 30 September 2011 until 30 June 2012. • EUR 15,000 if the player starts in 20 league games. • 4 flight tickets per year • Housing 9. On 14 July 2011, the player asked the club in writing to provide him with the air ticket in order for him to return to the club. In this letter, he stressed that he was in country B for vacation with the approval of the club. Furthermore, he put the club in default of payment of his salary as from April 2011 until June 2011 as well as the EUR 15,000 bonus in accordance with the agreement, setting the time limit of 18 July 2011 in order for the club to remedy the alleged breach. In his correspondence, the player further stressed that he was committed to comply with the employment contract. 10. On 19 July 2011, the player sent another default notice to the club warning the latter that he would consider the contractual relation terminated with just cause, if the club would not remedy the default by 20 July 2011. 11. On 21 July 2011, the player terminated the employment contract in writing invoking just cause. 12. On 20 August 2011, the player signed an employment contract with the Club B, from country P, valid as from the date of signature until 30 June 2015, in accordance with which the player was entitled to receive for the 2011-12 season the total amount of EUR 321,027.28 payable in 11 equal monthly instalments as from 10 September 2011. Claim of the player: 13. On 21 July 2011, the player lodged a claim against the club in front of FIFA maintaining that the club is to be held liable for breach of contract without just cause and payment of compensation. 14. Therefore, the player claims payment of the total amount of EUR 1,205,000, which was detailed as follows: a. EUR 30,000 as outstanding salary for April, May, and June 2011; b. EUR 15,000 as bonus for having started in 20 league games in the 2009-10 season; c. EUR 160,000 as compensation for breach of contract; d. EUR 1,000,000 based on clause 5.6 of the super league contract; e. 5% interest p.a. over the outstanding salaries; f. EUR 60,000 additional compensation corresponding to 6 months’ salary. 15. The player further asks that sporting sanctions be imposed on the club. 16. The player explains that whereas he has fully complied with his contractual obligations, the club failed to pay his remuneration between April 2011 and June 2011 as well as the EUR 15,000 bonus, totalling EUR 45,000. 17. The player deems that he had just cause to terminate the contract due to the club’s failure to remit his remuneration during at least 3 months. Response to the claim of the player and counterclaim of the club: 18. The club, for its part, rejects the player’s claim and, on 25 August 2011, lodged a counterclaim against him. 19. The club points out that with the signature of the employment contract, the player expressly consented to comply with the internal rules of the club, among which are the “Internal Regulation of 2010-2011” (hereinafter: internal rules). 20. The club holds that, in April 2011, the player left without the approval of or notification to the club, whereas the sporting season was still ongoing, and that he never returned to the club. 21. In addition, the club asserts that its efforts to contact the player to settle “the misunderstanding” have remained in vain. 22. The club further states that due to his long-lasting absence from the club’s training, a first fine of EUR 54,600 was imposed on the player on 15 May 2011 due to his absence as from 2 May 2011 in accordance with the club’s internal rules and that, on 16 July 2011, the player was imposed fines of EUR 96,600 for violations allegedly committed in the 2010-11 season and of EUR 54,000 for alleged contractual breaches during the 2011-12 season, respectively. 23. According to the club, the player was informed of the starting date of training for the 2011-12 season, i.e. 4 July 2011, and on 28 June 2011 it sent him the e-ticket to fly from country B to country G in order for the player to return to the club and attend training, as it was still counting on his services. 24. Therefore, the club holds that the player cannot justify his absence from training as of 4 July 2011 by lack of travel means. 25. In addition, the club points out that the player, due to the fines that were imposed on him, actually owes the amount of EUR 60,600 as outstanding fines to the club. In this respect, the club specified that the player had outstanding receivables of EUR 90,000 relating the period of time between 30 April 2011 and 30 June 2011, whereas he was fined the total amount EUR 150,600. 26. For these reasons, the club maintains that the player acted in breach of his contractual obligations and therefore, is to be held liable for the termination of the employment contract without just cause and payment of compensation to the club. 27. Consequently, the club asks that the player’s claim be dismissed and that it be established that the player terminated the employment contract without just cause within the protected period. 28. Furthermore, the club asks that the player be ordered to pay compensation for breach of contract in the amount of EUR 1,000,000 in accordance with art. 5.6 of the super league contract as well as the amount of EUR 60,600 relating to outstanding fines. 29. In addition, the club asks that sporting sanctions be imposed on the player and that he shall be held liable for legal expenses. Player’s reply to the club’s counterclaim: 30. The player contests that he left the club without approval or notification emphasising that he left for holidays after the end of the sporting season, which, according to the player, ended on 17 April 2011, date on which he played his last match of the season. He adds that all players were released to start their vacation after this match. 31. In this respect, the player refers to his correspondence of 14 July 2011, in which he also indicated that he was on vacation in country B with the club’s approval. 32. The player furthermore states that he never received the e-ticket that was presented by the club in support of its counterclaim and adds that only after his default notification to the club on 14 July 2011 did the club finally send him the flight tickets to return on 17 July 2011. 33. The player adds that the club, however, failed to remedy its default regarding the outstanding remuneration. 34. Furthermore, as regards the fines that the club imposed on him, the player states that the club never sent him a written warning regarding his alleged absence without approval and that he was not aware of any disciplinary procedure against him. He also expresses his doubts as to the calculation of the amount of the fines in the light of the wording of the club’s internal rules, which he considers vague. Position of Club B: 35. Club B holds that the player’s claim is to be accepted, since he had just cause to terminate his employment contract with the club, and that the club’s counterclaim is to be rejected. 36. Club B further maintains that it cannot be held responsible in any way in this matter and it insists that it did not induce the player to commit a breach of contract. It was in contact with the player after he had terminated his employment contract with the club and Club B stresses that it has no connection with such termination. II. Considerations of the Dispute Resolution Chamber 1. First of all, the Dispute Resolution Chamber (hereinafter also referred to as Chamber or DRC) analysed whether it was competent to deal with the matter at hand. In this respect, it took note that the present matter was submitted to FIFA on 21 July 2011. Consequently, the Rules governing the procedures of the Players’ Status Committee and the Dispute Resolution Chamber (edition 2008; hereinafter: Procedural Rules) are applicable to the matter at hand (cf. art. 21 par. 1 and par. 2 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 and par. 2 in combination with art. 22 lit. b of the Regulations on the Status and Transfer of Players (edition 2012) the Dispute Resolution Chamber is competent to deal with the matter at stake, which concerns an employment-related dispute with an international dimension between a country B player and a country G club and involving a country P club. 3. Furthermore, the Chamber analysed which regulations should be applicable as to the substance of the matter. In this respect, it confirmed that in accordance with art. 26 par. 1 and 2 of the Regulations on the Status and Transfer of Players (2012), and considering that the present claim was lodged on 21 July 2011, the 2010 edition of said regulations (hereinafter: Regulations) is applicable to the matter at hand as to the substance. 4. 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. 5. In this respect, the Chamber acknowledged that, on 15 August 2009, the Claimant/Counter-Respondent and the Respondent/Counter-Claimant signed a Greek super league contract as well as a “private agreement” (hereinafter together referred to as employment contract) valid during three seasons until 30 June 2012. 6. The Claimant/Counter-Respondent, on the one hand, maintains that he had just cause to terminate the employment contract on 21 July 2011, as the Respondent/Counter-Claimant had failed to comply with its financial obligations since April 2011 and that, therefore, the Respondent/Counter-Claimant was to be held liable for the early termination of the employment contract and payment of compensation in addition to allegedly outstanding remuneration. 7. The Chamber further noted that the Respondent/Counter-Claimant rejected the claim and held that the Claimant/Counter-Respondent terminated the employment contract without just cause, on the basis of which it lodged a counterclaim against the Claimant/Counter-Respondent. 8. In continuation, the Chamber took into account that the Claimant/Counter-Respondent fully rejected the Respondent/Counter-Claimant’s counterclaim. 9. Considering the diverging position of the parties, the members of the Chamber highlighted that the central issue in this dispute was to determine as whether the Claimant/Counter-Respondent had terminated the employment contract on 21 July 2011 with or without just cause as well as to decide on the consequences thereof. 10. Subsequently, the Chamber proceeded with an analysis of the circumstances surrounding the present matter, the parties’ arguments as well the documentation on file, bearing in mind art. 12 par. 3 of the Procedural Rules, in accordance with which any party claiming a right on the basis of an alleged fact shall carry the burden of proof. 11. In this respect, the Chamber recalled that, on 14 July 2011, the Claimant/Counter-Respondent served a first notice of default on the Respondent/Counter-Claimant setting a four days’ time limit to the Respondent/Counter-Claimant in order to comply with its contractual obligations relating inter alia to his remuneration as from April 2011 as well as an air ticket. The Chamber noted that, on 19 July 2011, a second default notice was sent by the Claimant/Counter-Respondent to the Respondent/Counter-Claimant and that, on 21 July 2011, the Claimant/Counter-Respondent terminated the employment contract invoking just cause. The members of the Chamber further took into account that the Respondent/Counter-Claimant has not replied to said default notices of the Claimant/Counter-Respondent. 12. The Respondent/Counter-Claimant, for its part, held that the Claimant/Counter-Respondent had no just cause to terminate the employment contract on 21 July 2011, since he had left the club without notification or its permission in April 2011 during the ongoing season. The Claimant/Counter-Respondent, for his part, indicated that he had left for vacation after the club’s last match. In this regard, the Respondent/Counter-Claimant highlighted that all of its efforts in contacting the Claimant/Counter-Respondent had remained in vain. The members of the Chamber, however, took into account that the Respondent/Counter-Claimant had not presented any documentary evidence demonstrating that it had, indeed, contacted the player, put the latter in default of his obligations, or warned him. 13. In addition, the Respondent/Counter-Claimant asserted that the Claimant/Counter-Respondent had been duly notified of the starting date of training for the new season and that, on 28 June 2011, it sent an air e-ticket to the Claimant/Counter-Respondent to return to the club on 3 July 2011, receipt of which was contested by the Claimant/Counter-Respondent, who asserted that he was provided with the relevant air ticket by the Respondent/Counter-Claimant to return on 17 July 2011, i.e. after having put the club in default on 14 July 2011, a copy of which was presented by the player. In this respect, the members of the Chamber noted that there was no evidence on file corroborating the Respondent/Counter-Claimant’s allegation that it transmitted the relevant return air e-ticket dated 28 June 2011 to the Claimant/Counter-Respondent. 14. The Chamber then turned its attention to the argument of the Respondent/Counter-Claimant relating to the fines that had been imposed on the Claimant/Counter-Respondent on the basis of the latter’s alleged absence from the club without its permission. The Respondent/Counter-Claimant, who does not contest that the Claimant/Counter-Respondent’s remuneration as of April 2011 had remained unpaid, held that the Claimant/Counter-Respondent in fact has a debt of EUR 60,600 towards it taking into consideration the fines totalling, according to the Respondent/Counter-Claimant, EUR 150,600. 15. In continuation, the members of the Chamber noted that in support of its position, the Respondent/Counter-Claimant presented a copy of the club’s “Internal Regulation of 2010-2011”, in accordance with which, after a previous written warning, 3% on the contractual instalments for each training missed shall be imposed as a fine. Furthermore, after 2 unjustified absences, the player shall be called to plea in front of the club’s disciplinary board. 16. The Chamber then focussed its attention on the contents of the respective decisions passed by the Board of the Respondent/Counter-Claimant. According to the decision passed on 15 May 2011, a fine of EUR 54,600 was imposed on the player due to his absence as from 2 May 2011, i.e. EUR 4,200 x 13 days. On 16 July 2011, the Respondent/Counter-Claimant’s Board imposed on the player a fine of EUR 96,600, i.e. EUR 4,200 per day of absence for 23 days until 25 May 2011, and a fine of EUR 54,000, i.e. EUR 4,500 per day of absence during 12 days of the 2011-12 season. 17. Regardless of the Chamber’s observation under point II./12. above, having duly taken note of the club’s internal rules and the aforementioned decisions, the Chamber deemed it important to highlight that these fines do not appear to have been issued in accordance with the stipulations of the club’s internal rules. What is more, the members of the Chamber agreed that the fines totalling the amount of EUR 150,600, bearing in mind that the first fine of EUR 54,600 seems to be included in the amount relating to the second fine of EUR 96,600, were considered clearly disproportionate to the Claimant/Counter-Respondent’s income. For these reasons, the Chamber decided that these fines shall be disregarded. 18. Furthermore, for the sake of good order, the Chamber wished to point out that the imposition of a fine, or any other available financial sanction in general, shall not be used by clubs as a means to set off outstanding financial obligations towards players. 19. On account of the aforementioned considerations, the Chamber established that the Respondent/Counter-Claimant had no valid reasons not to pay the Claimant/Counter-Respondent’s remuneration as of April 2011. 20. Taking into account all of the above, the Chamber decided to reject the arguments put forward by the Respondent/Counter-Claimant in its defence and in its counterclaim and decided that the Claimant/Counter-Respondent had just cause to terminate the employment contract on 21 July 2011. Hence, the members of the Chamber decided that the Respondent/Counter-Claimant is to be held liable for the early termination of the employment contract with just cause by the Claimant/Counter-Respondent. 21. In continuation, prior to establishing the consequences of the termination of the employment contract with just cause by the Claimant/Counter-Respondent in accordance with art. 17 par. 1 of the Regulations, the Chamber held that it had to address the issue of any unpaid remuneration at the moment the employment contract was terminated by the Claimant/Counter-Respondent. 22. In this regard, the members of the Chamber recalled that according to the Claimant/Counter-Respondent, his remuneration as of April 2011 until the end of June 2011 in the total amount of EUR 30,000 as well as a EUR 15,000 bonus for the 2009-10 season had remained unpaid. 23. The members of the Chamber further took into account that, as stated above, the Respondent/Counter-Claimant had not contested that the player’s remuneration as of April 2011 had remained outstanding and that it had no valid reasons justifying such non-payment. Consequently, the Chamber decided that, in virtue of the principle pacta sunt servanda, the Respondent/Counter-Claimant is liable to pay to the Claimant/Counter-Respondent the amount of EUR 30,000 that had remained outstanding in accordance with the private agreement on the day on which the Claimant/Counter-Respondent terminated the employment contract with just cause. 24. In addition, taking into consideration the Claimant/Counter-Respondent’s claim, the Chamber decided to award the Claimant/Counter-Respondent interest at the rate of 5% p.a. on the amount of EUR 30,000 as of the day on which the claim was lodged in front of FIFA, i.e. 21 July 2011. 25. Furthermore, in the absence of any documentary evidence demonstrating that the contractual condition related to Claimant/Counter-Respondent’s entitlement to the EUR 15,000 bonus in accordance with the private agreement was fulfilled (cf. art. 12 par. 3 of the Procedural Rules), i.e. the player having started in 20 league games, the Chamber decided to reject the Claimant/Counter-Respondent’s claim pertaining to said bonus. 26. Having established the above, the Chamber turned its attention to the question of the consequences of the termination of the employment contract by the Claimant/Counter-Respondent with just cause on 21 July 2011. 27. Taking into consideration art. 17 par. 1 of the Regulations, the Chamber concurred that the Claimant/Counter-Respondent, would, in principle, be entitled to receive an amount of money from the Respondent/Counter-Claimant as compensation for the termination of the contract with just cause in addition to any outstanding payments on the basis of private agreement. 28. Subsequently, the Chamber focused its attention on the calculation of the amount of compensation for breach of contract in the case at stake. In doing so, the members of the Chamber 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 Claimant 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. 29. In application of the relevant provision, the Chamber held that it first of all had to clarify as to whether the pertinent employment contract contains a provision by means of which the parties had beforehand agreed upon an amount of compensation payable by the contractual parties in the event of breach of contract. In this respect, the members of the Chamber recalled that according to art. 5.6 of the super league contract, which article was equally invoked by the Claimant/Counter-Respondent in his claim for compensation for breach of contract, “The player is entitled to buy the remainder of his contract, by paying out to the Club the amount of 1,000,000 EUR”. The Chamber, however, agreed that said clause does not regulate compensation payable in the event of a breach of the employment contract by either of the parties and, thus, that it cannot be taken into consideration in this context. 30. In continuation, the Chamber established that the reference of the super league contract to “art. 17 par. 2 of the Regulations” in connection with compensation for breach of contract in the event of the parties terminating the contract without just cause is insufficiently clear for it to be taken into consideration in the determination of the amount of compensation. 31. As a consequence, the members of the Chamber determined that the amount of compensation in the present matter had to be assessed in application of the other parameters set out in art. 17 par. 1 of the Regulations. The Chamber recalled that said provision provides for a non-exhaustive enumeration of criteria to be taken into consideration when calculating the amount of compensation payable. Therefore, other objective criteria may be taken into account at the discretion of the deciding body. In this regard, the Dispute Resolution Chamber emphasised beforehand that each request for compensation for contractual breach has to be assessed by the Chamber on a case-by-case basis taking into account all specific circumstances of the respective matter. 32. In order to estimate the amount of compensation in the present case, the members of the Chamber first turned their attention to the remuneration and other benefits due to the Claimant under the existing contract and/or the new contract, which criterion was considered by the Chamber to be essential. The members of the Chamber deemed it important to emphasise that the wording of art. 17 par. 1 of the Regulations allows the Chamber to take into account both the existing contract and the new contract, if any, in the calculation of the amount of compensation. 33. Bearing in mind the foregoing, the Chamber proceeded with the calculation of the monies payable to the player under the terms of the private agreement for the remaining duration until 30 June 2012 and concluded that the Claimant/Counter-Respondent would have received a total remuneration of EUR 160,000. 34. In continuation, the Chamber verified as to whether the Claimant/Counter-Respondent had signed an employment contract with another club during the relevant period of time, by means of which he would have been enabled to reduce his loss of income. According to the constant practice of the DRC, such remuneration under a new employment contract shall be taken into account in the calculation of the amount of compensation for breach of contract in connection with the player’s general obligation to mitigate his damages. 35. Indeed, on 20 August 2011, the Claimant/Counter-Respondent signed an employment contract with the Club B, from country P, valid as from the date of signature until 30 June 2015, in accordance with which the player was entitled to receive for the 2011-12 season the total amount of EUR 321,027.28 payable in 11 equal monthly instalments as from 10 September 2011. 36. Consequently, the Chamber established that the value of the new employment contract concluded between the Claimant/Counter-Respondent and his new club for the period of time between July 2011 and 30 June 2012 amounted to EUR 291,842. 37. In accordance with the constant practice of the Dispute Resolution Chamber and the general obligation of the player to mitigate his damages, such remuneration under the new employment contract shall be taken into account in the calculation of the amount of compensation for breach of contract. 38. Consequently, on account of all of the above-mentioned considerations and the specificities of the case at hand, the Dispute Resolution Chamber decided that, even though the Respondent/Counter-Claimant is considered liable for the early termination of the employment contract, the Claimant/Counter-Respondent did not suffer any financial loss from the violation of the contractual obligations by the Respondent/Counter-Claimant and, therefore, the Chamber decided that there is no amount that should be awarded to the Claimant/Counter-Respondent as compensation for breach of contract in the matter at hand. 39. The members of the Chamber concluded their deliberations on the present matter by rejecting any further claim lodged by the Claimant/Counter-Respondent. III. Decision of the Dispute Resolution Chamber 1. The claim of the Claimant/Counter-Respondent, Player F, is partially accepted. 2. The counterclaim of the Respondent/Counter-Claimant, Club K, is rejected. 3. The Respondent/Counter-Claimant has to pay to the Claimant/Counter-Respondent, within 30 days as from the date of notification of this decision, the amount of EUR 30,000 plus 5% interest p.a. as from 21 July 2011 until the date of effective payment. 4. In the event that the amount due to the Claimant/Counter-Respondent is not paid by the Respondent/Counter-Claimant within the stated time limit, the present matter shall be submitted, upon request, to the FIFA Disciplinary Committee for consideration and a formal decision. 5. Any further claim lodged by the Claimant/Counter-Respondent is rejected. 6. The Claimant/Counter-Respondent is directed to inform the Respondent/Counter-Claimant immediately and directly of the account number to which the remittance is to be made and to notify the Dispute Resolution Chamber of every payment received. ***** Note relating to the motivated decision (legal remedy): According to art. 67 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, a copy of which we enclose hereto. 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 www.tas-cas.org For the Dispute Resolution Chamber: Markus Kattner Deputy Secretary General Encl.: CAS directives