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 20 May 2020

Decision of the

Dispute Resolution Chamber

passed in Zurich, Switzerland, on 20 May 2020,

in the following composition:

Geoff Thompson (England), Chairman

Jerome Perlemuter (France), member

Angela Collins (Australia), member

on the claim presented by the player,

Player A, Country B

as Claimant / Counter-Respondent I

against the club,

Club C, Country D

as Respondent / Counter-Claimant

with the club,

Club E, Country B

as Counter-Respondent II

regarding an employment-related dispute

between the parties

I. Facts of the case

1. On 1 August 2017, the player of Country B, Player A (hereinafter: the player or the Claimant) and the club of Country D, Club C (hereinafter: the club or the Respondent) signed an employment contract valid as from the date of its signature until 30 June 2021 by means of which the player was hired to exercise his professional football activity under the category of senior.

2. The contract provided for the player to receive the following remuneration from the club: EUR 31,735 gross during the 2017/2018 season; EUR 34,620 gross during the 2018/2019 season and EUR 34,620 gross during the 2020/2021 season. The player’s salary during the seasons 2018/2019, 2019/2020 and 2020/2021 was payable in 12 equal instalments, the first to be paid on 10 August of the respective season and the remainder on the same day of the subsequent months.

3. In case of an early termination of the contract without just cause or in case of breach of contract by the Claimant, the latter had to pay, as compensation, the sum of EUR 20,000,000 to the Respondent (cfr. Clause 11 of the contract).

4. In accordance with clause 12 of the contract, the Claimant could terminate his relationship with the Respondent by paying to the latter the amount of EUR 25,000,000 provided the termination occurred during one of the registration period established at national level and that the Respondent received the sum of EUR 20,000,000.

5. By means of a correspondence dated 24 October 2019, the Claimant terminated the contract. In the relevant document, the Claimant accused the Respondent of having failed to register his contract with the professional league of Country D and pointed out that, as a result, he had been unable to participate in the categories A and B of the league during the 2019/2020 season. The Claimant added that he had not been allowed to participate as a professional player in the categories for which he had been hired.

6. In response thereto, on 28 October 2019, the Respondent informed the Claimant that it deemed that the latter’s termination of contract had occurred without just cause. The Respondent also warned the Claimant of the consequences of a unilateral termination included in the clauses 11 and 12 of the contract (cfr. Point 11 and 12 above).

7. On 4 December 2019, the player ratified the termination of the contract.

8. On 1 January 2020, the Claimant lodged a claim with FIFA against the Respondent for breach of contract and requested from the latter the payment of compensation for breach of contract as follows: EUR 20,000,000 as per clause 11 of the contract and EUR 60,585 corresponding to the remaining value of the contract.

9. In addition, the Claimant requested FIFA to sanction the Respondent in accordance with art. 17 par. 4 of the Regulations on the Status and Transfer of Players (hereinafter: the Regulations).

10. The Claimant explained that because of the Respondent’s failure to register the contract with the Football League of Country D, he had been prevented from playing in any official match with the team during the 2019/2020 season.

11. According to the Claimant, the Respondent had unilaterally decided not to proceed with the registration of the contract without informing him.

12. From the Claimant’s point of view the Respondent had neglected to register his contract with the league in question because he was no longer interested in his services.

13. The Claimant added that the Respondent’s behaviour had put his career at risk.

14. In continuation, the Claimant emphasised that players have the right to render the services for which they have been hired, i.e. playing football and stressed that had been employed as senior player.

15. In view of all of the aforementioned, the Claimant was of the opinion that the Respondent had breached the contract. As a result, the Claimant deemed having had just cause to terminate the contract on the basis of art. 14 of the Regulations.

16. In this context, the Claimant also underlined that in accordance with the jurisprudence of FIFA and of CAS, failure by a club to register a player violates the latter’s right to play and is therefore considered as just cause to terminate the contract.

17. Additionally, the Claimant mentioned that the Respondent stopped paying his salary in October 2019.

18. Subsequently, the Claimant referred to art. 17 of the Regulations and pointed out that the contract had been terminated within the protected period.

19. In the same context, the Claimant referred to clause 11 of the contract and argued that the provision in question was applicable also in case the termination of contract was caused by the Respondent. As a result, the Claimant deemed that the Respondent had to pay him EUR 20,000,000.

20. In the alternative, the Claimant requested the payment of the remaining value of the contract, i.e. the sum of EUR 60,585.

21. Finally, the Claimant deemed that sanctions should be imposed on the Respondent in line with art. 17 par. 4 of the Regulations.

22. In its response on 2 February 2020, the Respondent rejected the claim of the Claimant and lodged a counterclaim against the latter.

23. In this respect, and to begin with, the Respondent argued that, after having terminated the contract, the Claimant had concluded an employment contract with the club of Country B, Club E (hereinafter: “Club E”) and that on 30 October 2019, the Football Federation of Country D had issue a “provisional certificate” enabling the Claimant to play with such club. The Respondent considered “crystal clear” that Club E had induced the Claimant into terminating the contract without just cause “in order to sign [him] for free”.

24. In continuation, the Respondent contested the allegation of the Claimant that it would have not registered the contract with the League of Country D and pointed out that it had proceeded with a first registration on 22 August 2017 and to two subsequent renewals of such registration on 1 August 2018 and 22 July 2019 respectively. As to that, the Respondent provided FIFA with a document, written in language of Country D and issued by the Football League of Country D. In accordance with a free translation of the document in question, the player “in the sports seasons 2017/2018 and 2018/2019 took part in official games on behalf of Club C, in the context of competitions organized under the auspice of the League of Country D, according to which resulted the sports histories of the player, extracted from our database, database F, and which are attached. I also advise that according to the information also recorded, regarding the sports season, 2019/2020, this player does not have any recorded activity”.

25. According to the Respondent, the Claimant “participated in 08 official Second Divisions games of the 2017/2018 season, and as the 2018/2019 season came to pass, he took part in 07 official games of the following competitions: 2 in the Second Division, representing “Club C” and 5 in the “Under

23 League””. Equally, the Respondent alleged that, on 27 January 2019, “the Claimant scored (..) the victory goal for the “Under 23 team” of the Respondent in an official game (..)”.

26. The Respondent further pointed out that “contrary to the assertion by the Claimant (..) it is entirely false that he did not participate in any game or was ever barred from participating in games by main team or any other Respondent teams. It is equally false that the Claimant was not registered or that he was unable to play of that circumstance”.

27. In addition, the Respondent alleged having always paid the Claimant’s salary and maintained having unsuccessfully tried to solve the dispute at stake in an amicable way.

28. In continuation and as to the 2019/2020 season, the Respondent explained that the Claimant’s non participation in any match “until 16 October 2019” had been a consequence of “technical choices” and added that “after that” he “did not participate in further games (…) following an injury that made him unable to participate in any of the games.”

29. In view of all of the aforementioned, the Respondent deemed that the termination of contract by the Claimant had occurred without just cause.

30. Subsequently, the Respondent contested having had the intention “or deliberation to push away the Claimant, considering that he was always part of the Respondent’s senior squad and took part in training sessions and official games or competitions for the team.”

31. From the Respondent’s point of view, the Claimant’s decision to terminate the contract had been a consequence of the “frustration, disappointment or disillusion felt after not playing a single official game for the Respondent’s main team. (..) However the desires, aspirations or conjectures by the Claimant do not constitute strong enough foundations for the unilateral termination of the work contract.”

32. The Respondent further referred to Swiss Law and added that the “simple fact of the player not playing for the main team – despite being involved in competitions in other Respondent squad – does not constitute any breach of [its] legal duties, considering that the player has always had at his disposal all the means – technical, legal and material – to duly perform the job for which he was hired.”

33. Equally, the Respondent maintained that the Claimant was never promised a permanent spot in the main team. The Respondent was of the opinion that the contract did not include any obligations “to participate in games by the professional team” and it only indicated “that the Claimant” had to perform his activity “as a professional footballer within the scope of the Respondent’s “senior football” team.” In this context, the Respondent further argued that “senior football” contemplates all competitions where the athletes are at least 19 years old.”

34. The Respondent continued by contesting the applicability of clause 11 of the contract on a termination of contract by the Claimant pointing that out that it was not “factual that the clause is defined to “benefit both parties”” as alleged by the Claimant.

35. In conclusion, the Respondent argued that because the Claimant had terminated the contract without just cause, it was entitled to claim from the latter the payment of the sum of EUR 20,000,000 in accordance with clause 11 of the contract.

36. The Respondent also requested the payment of 5% interest p.a. on the sum of EUR 20,000,000 as of 23 October 2019.

37. In the alternative, the Respondent requested to receive the appropriate compensation under art. 17 par. Of the Regulations on the Status and Transfer of Players “with the corresponding interests at the rate of five percent (…) as of 23rd October 2019” and “to impose on the Claimant a four-month restriction on playing in official matches according to art. 17 of FIFA RSTP.”

38. By means of a correspondence dated 27 March 2020, the Claimant provided FIFA with his response as to the counterclaim of the Respondent and rejected the allegation of the latter.

39. In this respect, the Claimant contested the allegation that he could have played with the senior team of the Respondent during the 2019/2010 and argued that he did not conclude an employment contract with Club E before terminating the contract.

40. The Claimant further pointed out that the Football Federation of Country D issued his ITC only after an intervention of the Single Judge of FIFA.

41. Additionally, the Claimant contested not having been in the position to play during the 2019/2020 season due to an injury.

42. The Claimant argued once again that he had had just cause to terminate the contract as the Respondent had prevented him from playing with its team by failing to register his contract with the league. As to that, the Claimant provided FIFA with an email written in language of Country D by the League of Country D on 4 October 2019. In accordance with a free translation into Spanish of the document in question it is confirmed that although the contract had been registered with the league, the Claimant could not play during the 2019/2020 seasons because not all formal requirements necessary to his registration and licence had been complied with, i.e. his enrolment with the club and the documents which confirmed his physical aptitude.

43. As a result, the Claimant deemed that the counterclaim of the Respondent had to be rejected and that his original claim was to be accepted.

44. On 27 March 2020, Club E provide its position in the dispute at stake and rejected the counterclaim of the Respondent.

45. In this respect, Club E pointed out that the Claimant had had just cause to terminate the contract and argued that it only conclude an employment contract with the latter after the relevant termination of contract had occurred.

46. In addition, Club E maintained that the ITC of the player had not been issued on 30 October 2019 but only after the intervention of FIFA. Club E added that it had only requested the ITC of the Claimant on 9 January 2020.

47. Club E further contested the allegation of the Respondent that the Claimant would have not been in the position to play during the 2019/2020 season in view of an injury.

48. In continuation, Club E pointed out that the Claimant had been hired as senior player by the Respondent and that by not allowing him to play in the Football League of Country D the Respondent had breached the contract.

49. Finally, Club E contested the allegation that it would have induced the Claimant into terminating the contract.

50. With regard to his employment situation, the Claimant executed an employment contract with Club E on 9 January 2020, valid from 27 December 2019 until the end of the 2023 season in accordance with which the Claimant was entitled to receive, as remuneration, the monthly amount of 900,000 in the currency of Country B.

II. Considerations of the Dispute Resolution Chamber

1. First of all, the Dispute Resolution Chamber (hereinafter: the DRC or the Chamber) analyzed whether it was competent to deal with the case at hand. In this respect, the DRC took note that the present matter was submitted to FIFA on 1 January 2020. Consequently, the Chamber concluded that the November 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 (edition 2020) 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 club of Country D and a player of Country B.

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, and considering that the present claim was lodged on 1 January 2020, the October 2019 edition of said regulations (hereinafter: the 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 doing so, the DRC continued by acknowledging the above-mentioned facts as well as the documentation contained in the file in relation to the substance of the matter. 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 recalled that the parties had concluded an employment contract valid as of 1 August 2017 until 30 June 2021.

6. Subsequently, the Chamber noted that the Claimant had lodged a claim with FIFA against the Respondent requesting the payment of compensation for breach of contract arguing that he had terminated the contract on 23 October 2019 with just cause.

7. Equally, the Chamber observed that for its part, the Respondent had contested the claim of the Claimant maintaining that the latter had not had just cause to terminate the contract and had lodged a counterclaim against the latter requesting the payment of compensation for breach of contract.

8. In line with the above, the DRC highlighted that the first issue in the matter at stake would be to determine as to whether the contract was terminated with or without just cause by the Claimant and to decide on the consequences thereof.

9. With the above in mind, 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.

10. In this respect and to begin with, the Chamber wished to recall that the Claimant had argued having terminated the contract because the Respondent had omitted to register the contract with the league of Country D for the 2019/2020 season and that, as a consequence, he had been prevented from playing in any match with the team.

11. Similarly, the DRC took into account that the Respondent had contested the aforementioned allegation of the Claimant alleging inter alia that the latter had not played during the season in question due to a technical decision and that he had been injured.

12. In continuation, the DRC noticed that, as evidence, the Respondent had provided a statement of the Football League of Country D in which it was mentioned that the player had taken part in official matches with the team of the Respondent during the sports seasons 2017/2018 and 2018/2019 “in the context of competitions organized under the auspice of the League of Country D” and that there was no record of the Claimant’s participation in any match during the 2019/2020 season.

13. Equally, the Chamber recalled that the Claimant had provided an email written by the Football League of Country D indicating that he had not been eligible to play for the Respondent during the 2019/2020 season as not all formal requirements had been complied with.

14. In this context, the members reverted to art. 12 par. 3 of the Regulations and turned their attention to the different evidences provided by the parties in support of their respective allegations.

15. By doing so, the DRC referred to the statement of the Leagues of Country D provided by the Respondent and pointed out that the document in question indicated that the Claimant had played several matches during the seasons 2017/2018 and 2018/2019 and none during the 2019/2020 season.

16. In addition, the DRC analysed the email of the League of Country D provided by the Claimant and stressed that it clearly confirmed that the latter had not been entitled to play during the 2019/2020 because not all formal requirements necessary to his registration and licence had been complied with.

17. Taking into account the aforementioned email as well as the confirmation provided by the Respondent that the Claimant had not been fielded in any match during the 2019/2020, the DRC came to the conclusion that, in accordance with the evidence on file, it had been demonstrated that the Claimant had not been eligible to play during the 2019/2020 season as a result of the Respondent’s negligence to successfully register him with the league.

18. After having established the aforementioned, the Chamber considered important to underlined, that, in accordance with its well established jurisprudence, one of players’ fundamental rights under an employment contract is not only to receive a timely payment of their remuneration but also to have access to training and to be given the possibility to compete with their fellow team mates in the team’s official matches.

19. In this context, the DRC emphasized that in principle, by not registering a player, a club is effectively barring, in an absolute manner, his potential access to competition and, as such, is violating one of his fundamental rights as a football player.

20. In continuation and with regard to the fact that the Claimant did not seem to have put the Respondent in default before terminating the contract, the DRC wished to highlight that, considering the circumstances, i.e. the fact that the deadline for the registration of the player with the League of Country D had already elapsed and that therefore the latter could no longer be registered to play for the season in question, in casu a default notice would have been of no use and would have not changed the situation of the player.

21. As a result of all of the aforementioned and in particular considering that by not registering the Claimant with the Football League of Country D the Respondent had violated one of his fundamental rights, the DRC came to the conclusion that the Claimant had just cause to terminate the contract.

22. Having established the aforementioned and considering that the Claimant had not requested the payment of outstanding remuneration, the Chamber focused its attention on the calculation of the amount of compensation payable to the Claimant by the Respondent for breach of contract in.

23. 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 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. Bearing in mind the aforementioned principles, the Chamber further referred to the contents of art. 17 par. 1 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”).

24. In application of the relevant provision, the Chamber held that it first of all had to clarify whether the contract at the basis of the present dispute contain 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.

25. In this regard, the Chamber took into account that the Claimant had inter alia requested to be awarded, as compensation, the sum of EUR 20,000,000 in accordance with clause 11 of the contract.

26. Bearing in mind the aforementioned, the DRC turned its attention to the content of the clause in question and stressed that it was clearly only in favour of the Respondent and was therefore not applicable.

27. Similarly, the DRC wished to underline that also clause 12 of the contract was only in favour of the Respondent and, as a result, was not applicable.

28. As a consequence of the above, the members of the Chamber determined that the amount of compensation payable by the Respondent to the Claimant had to be assessed in application of the 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 emphasized 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.

29. In doing so, the Chamber calculated that the remaining value of the contract amounted to EUR 58,373, corresponding to: EUR 673 for 7 days of salary of October 2019; EUR 23,080 for the last 8 remaining months of the 2019/2020 season and EUR 34,620 for the 2020/2021 season.

30. Thus, the Chamber deemed that the sum of EUR 58,373 had to serve as the basis for the final determination of the amount of compensation for breach of contract.

31. In continuation, the Chamber verified as to whether the Claimant 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.

32. The Chamber noted in this regard that the player had concluded a contract with Club E by means of which he was entitled to receive a monthly salary of 900,000 in the currency of Country B which corresponded to approximately EUR 1,054 when the relevant contract was signed.

33. The DRC further calculated that between the termination of the contract and 30 June 2021, the contract with Club E provided for the Claimant to receive the total amount of EUR 18,972.

34. The DRC further established that the aforementioned amount of EUR 18,972 was to be deducted from the amount of EUR 58,373

35. Consequently, on account of all of the above-mentioned considerations and the specificities of the case at hand, the Chamber decided the amount of EUR 39,401 was to be considered reasonable and proportionate as compensation for breach of contract in the case at hand.

36. As a result, the DRC decided that the Respondent has to pay to the Claimant the sum of EUR 39,401 as compensation for breach of contract.

37. In view of all of the aforementioned, the DRC concluded that the claim of the Claimant is partially accepted and that the Respondent has to pay to the Claimant the sum of EUR 39,401 as compensation for breach of contract.

38. Having established the aforementioned, the DRC turned its attention to the counterclaim of the Respondent.

39. In this respect and taking into account that the claim of the Claimant was partially accepted and that the termination of contract by the Claimant had occurred with just cause in view of the breach of contract committed by the Respondent, the DRC decided that the counterclaim of the latter is rejected.

40. Thereafter, taking into account the previous considerations, 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.

44. The Dispute Resolution Chamber concluded its deliberations in the present matter by establishing that any further claims lodged by the parties are rejected.

III. Decision of the Dispute Resolution Chamber

1. The claim of the Claimant / Counter-Respondent I, Player A, is partially accepted.

2. The counterclaim of the Respondent / Counter-Claimant, Club C, is rejected.

3. The Respondent / Counter-Claimant, Club C, has to pay to the Claimant / Counter-Respondent I compensation for breach of contract in the amount of EUR 39,401.

4. Any further claim lodged by the Claimant / Counter-Respondent I is rejected.

5. The Claimant / Counter-Respondent I is directed to inform the Respondent / Counter-Claimant, immediately and directly, preferably to the e-mail address as indicated on the cover letter of the present decision, of the relevant bank account to which the Respondent / Counter-Claimant must pay the amount mentioned under point 3. above.

6. The Respondent / Counter-Claimant shall provide evidence of payment of the due amount in accordance with point 3. above to FIFA to the e-mail address psdfifa@fifa.org, duly translated, if need be, into one of the official FIFA languages (English, French, German, Spanish).

7. In the event that the amount due plus interest in accordance with point 3. above is not paid by the Respondent / Counter-Claimant within 45 days as from the notification by the Claimant / Counter-Respondent I of the relevant bank details to the Respondent / Counter-Claimant, the Respondent / Counter-Claimant 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).

8. The ban mentioned in point 7. above will be lifted immediately and prior to its complete serving, once the due amount is paid.

9. In the event that the aforementioned sum plus interest is 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.

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 Procedural Rules).

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.

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 / Fax: +41 21 613 50 01

e-mail: info@tas-cas.org / www.tas-cas.org

For the Dispute Resolution Chamber:

Emilio García Silvero

Chief Legal & Compliance Officer