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 9 April 2020
Decision of the
Dispute Resolution Chamber
passed in Zurich, Switzerland, on 9 April 2020,
in the following composition:
Geoff Thompson (England), Chairman
Roy Vermeer (The Netherlands), member
Daan de Jong (The Netherlands), member
on the claim presented by the player,
Wilfried Joselin Sabaly Domoraud, France,
represented by Mr Georgi Gradev
as Claimant
against the club,
Hamrun Spartans FC, Malta,
represented by Ms Tracy Cauchi
as Respondent
regarding an employment-related dispute between the parties
I. Facts of the case
1. On 24 October 2018, the French player, Mr Wilfried Joselin Sabaly Domoraud, (hereinafter: the player or the Claimant) and the Maltese club, Hamrun Spartans FC (hereinafter: the club or the Respondent) signed an employment contract (hereinafter: the contract), valid for the season 2018/2019.
2. According to the contract, the Claimant was entitled to a monthly salary of EUR 1,000, as well as the following bonuses:
EUR 3,000 “if he scores 15 goals in the Maltese Premier League during season 2018/2019”;
EUR 3,000 “if the Club qualifies to play in UEFA Competition”.
3. In addition to the above, the Respondent also undertook to provide the Claimant with a car and “suitable accommodation”.
4. Moreover, art. 5.5 of the contract stipulated that “both parties agree to resolve any disputes between them through the various boards of the MFA and recognize the final jurisdiction of the Court of Arbitration of Sport (CAS) in Lausanne Switzerland”.
5. Pursuant to art. 1.3 of the contract, the Respondent had the possibility to extend the duration of the contract for another year, i.e. the season 2019/2020. In the event of an extension, the salary of the Claimant shall be increased to EUR 3,000 per month.
6. By means of a letter dated 26 April 2019, the Respondent informed the Claimant that it “has decided to take up the option referred to in Clause 1.3 of the said agreement and extends the same contract for another year, namely, season 2019/20.” Moreover, the Respondent indicated that it “confirms that the salary of the player shall be increased to Euro 3,000 (three thousand euro) per month”.
7. On 1 November 2019, the Claimant granted the Respondent 15 days to pay the outstanding salaries of the months of July, August, September and October 2019, in the amount of EUR 12,000.
8. On 5 December 2019, the Claimant terminated the contract and lodged a claim against the Respondent in front of FIFA. However, the Claimant then decided to withdraw his termination and on 9 December 2019 granted the Respondent 15 days to comply with its contractual obligations and to pay his monthly salaries of September until November 2019. Finally, the Claimant withdrew his claim in front of FIFA on 15 December 2019.
9. On 22 December 2019, the Respondent acknowledged having a debt in favour of the Claimant in the amount of EUR 4,755, after deduction of expenses, i.e. apartment costs, car related costs, etc. On 27 December 2019, the Claimant replied, rejecting the deductions made by the Respondent, claiming that the contract “does not provide for a possible set off between the salary against the expenses”.
10. On 1 January 2020, the Claimant terminated the contract (hereinafter: the termination notice), invoking the Respondent’s non-compliance with its financial obligations, in particular, the player highlighted that the club failed to pay 4 monthly salaries, i.e. September to December 2019.
11. On 3 January 2020, the Respondent confirmed that salaries of September 2019 until November 2019 were due. However, the Respondent considered that pursuant to the contract, it was only bound to “pay the player a monthly salary and to provide him with a car and suitable accommodation” and therefore “the ancillary expenses are not catered for […] and shall be refunded to the Club.” As such, the Respondent concluded that the “remaining amount of EUR 4,755 in favour of the Player” constituted less than two salaries, thus not entitling the Claimant to terminate the contract with just cause.
12. On 8 January 2020, the Claimant lodged a claim in front of FIFA against the Respondent.
13. In his claim, the Claimant held that “as of 1 July 2019” he “rendered services for the Respondent without any pay at all.” This being said, the Claimant acknowledged receipt of EUR 6,000, corresponding to monthly salaries of July and August 2019.
14. With regard to the withdrawal of his first claim in front of FIFA on 15 December 2019, the Claimant explained having “played in a championship match for the Respondent’s team.”
15. The Claimant further held that on 22 December 2019, the Respondent “for the very first time since the Contract claimed a deduction from the outstanding amounts […], without a legal basis and without providing evidence of a valid payment.” Moreover, the Claimant stated that the bills provided by the Respondent do not name him and are not related to the period of the outstanding salaries. The Claimant also maintained that, “[t]here is no written agreement between the Parties for the Claimant to contribute to the apartment rent.”
16. According to the Claimant, by “failing to pay [him], the Respondent implicitly acknowledged that it has no interest in the services of the Claimant and the future performance of the contract.” In these circumstances, the Claimant considered to have terminated the contract with just cause.
17. In light of the above, the Claimant requested the following:
Outstanding remuneration in the total amount of EUR 12,000, corresponding to his monthly salaries of the months of October 2019, November 2019, December 2019 and January 2020, plus 5% interest p.a. until the date of effective payment;
Compensation in the amount of EUR 12,000, plus 5% interest p.a. until the date of effective payment;
Additional compensation in the amount of EUR 9,000, corresponding to three monthly salaries.
18. Finally, the Claimant requested the imposition of sporting sanctions on the Respondent.
19. In its reply, the Respondent first rejected FIFA’s competence and referred to art. 5.5 of the contract.
20. With regard to the merits of the case, the Respondent rejected the Claimant’s claim, arguing that at the time of the termination, the Claimant owed the Respondent “the amount of EUR 4,447.74”. As such, the Respondent deemed that the outstanding remuneration due to the Claimant was less than three monthly salary and accordingly considered that the Claimant terminated the contract without just cause.
21. This being said, the Respondent acknowledged that, in principle, it owed the Claimant the salaries of September, October and November 2019 in the total amount of EUR 9,000, however, from this amount it had to deduct certain “expenses”, as follows:
Water and electricity bill: EUR 602.88.
Cost of repairs of the car: EUR 660.80. According to the Respondent, the Claimant was involved in 2 traffic accidents. The Respondent explained having obtained “an accurate quotation of costs”, however, “the Club has not repaired the vehicle which is why it does not have any receipts of such in possession”.
Traffic Fines: EUR 151.39.
Social security contributions from January to December 2019: EUR 1,832.67.
Additional rental fees: EUR 1,200 (September to December 2019). According to the Respondent, the parties agreed that it will pay EUR 500 per month for the Claimant’s apartment.
22. After being requested, the Claimant informed FIFA that he concluded an employment contract with the Maltese club, Gzira United FC, valid as from 8 January 2020 for “2 (two) seasons”, pursuant to which he was entitled to a monthly remuneration of EUR 850.
II. Considerations of the Dispute Resolution Chamber
1. First of all, the Dispute Resolution Chamber (hereinafter also referred to as: the DRC or the Chamber) analysed whether it was competent to deal with the case at hand. In this respect, the Chamber took note that the present matter was first submitted to FIFA on 8 January 2020. Consequently, 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 and 2 in combination with art. 22 lit. b) of the Regulations on the Status and Transfer of Players (March 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 French player and a Maltese club.
3. However, the Chamber acknowledged that the Respondent contested the competence of FIFA’s deciding bodies on the grounds of art. 5.5 of the contract, according to which “(b)oth parties agree to resolve any disputes between them through the various boards of the MFA and recognize the final jurisdiction of the Court of Arbitration of Sport (CAS) in Lausanne Switzerland”.
4. In this regard, the Chamber deemed it vital to outline that one of the basic conditions that needs to be met in order to establish that another organ than the DRC is competent to settle an employment-related dispute between a club and a player of an international dimension is that the jurisdiction of the relevant national arbitration tribunal or national court derives from a clear reference in the contract.
5. Therefore, while analysing whether it was competent to hear the present matter, the Dispute Resolution Chamber considered that it should, first and foremost, analyse whether the contract at the basis of the present dispute contained a clear and specific jurisdiction clause.
6. Having examined the relevant provision, the Chamber came to the unanimous conclusion that art. 5.5 of the contract does not constitute a clear jurisdiction clause in favour of one specific deciding body, since it is drafted in a generic manner. Moreover, the Chamber noted that the Respondent failed to provide any documents in regards to the “competent board of the Malta Football Association”. In this context, the Chamber understood that the parties actually never clearly and undisputedly agreed upon a specific jurisdiction. Consequently, the Chamber established that the Respondent’s objection towards the competence of FIFA to deal with the present matter has to be rejected, and that the Dispute Resolution Chamber 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.
7. In continuation, the DRC analysed which edition of the 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 (March 2020 edition) and considering that the present matter was submitted to FIFA on 8 January 2020, the January 2020 edition of said Regulations is applicable to the present matter as to the substance.
8. With the above having been established, the Chamber entered into the substance of the matter. In doing so, it started to acknowledge the facts of the case as well as the documents contained in the file. However, the Chamber emphasized that in the following considerations it will refer only to 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 FIFA Transfer Matching System (hereinafter: TMS).
9. In this respect, the Chamber firstly acknowledged that it was undisputed that the Claimant and the Respondent had signed an employment contract on 24 October 2018, valid for the season 2018/2019. In continuation, the Chamber noted that it was also undisputed that the contract had been extended on 26 April 2019, for the season 2019/2020, thereby increasing the Claimant’s monthly salary from EUR 1,000 to EUR 3,000.
10. What is more, the Chamber further noted that on 1 January 2020, the Claimant unilaterally terminated the employment contract with the Respondent, alleging that his salaries from September to December 2019 remained outstanding.
11. Summarising the parties’ respective positions in this dispute, the members of the Chamber noted that the Claimant, on the one hand, claimed that the Respondent had breached the contract by not paying him 4 monthly salaries, whilst on the other hand, the Respondent affirmed that at the time of the termination, the Claimant owed the Respondent the amount of EUR 4,447.74. However, the Chamber noted that the Respondent acknowledged that the amount of EUR 9,000 was due to the Claimant, but after the deduction of the abovementioned EUR 4,447.74, the Respondent stressed that less than 3 monthly salaries were in fact due to the Claimant at the time of the termination of the contract.
12. In view of the foregoing, the Chamber established that the main issue to be analysed in the present case is whether the Claimant in fact had a just cause to unilaterally and prematurely terminate the contract with the Respondent on 1 January 2020 or not. Subsequently, the Chamber shall establish the financial and/or sporting consequences to be borne by the party found to be in breach of contract.
13. In this respect, the Chamber was eager to emphasise that only a breach or misconduct which is of a certain severity justifies the termination of a contract. In other words, only when there are objective criteria which do not reasonably permit to expect a continuation of the employment relationship between the parties, a contract may be terminated prematurely. Hence, if there are more lenient measures which can be taken, such measures must be taken before terminating an employment contract. A premature termination of an employment contract can only ever be an ultima ratio measure.
14. Furthermore, the members of the Chamber deemed it appropriate to recall the basic principle of burden of proof, as stipulated in art. 12 par. 3 of the Procedural Rules, according to which a party claiming a right on the basis of an alleged fact shall carry the respective burden of proof.
15. In this context, the Chamber noted that the Claimant based the termination of the contract on the non-payment of 4 monthly salaries, i.e. from September to December 2019.
16. On the other hand, the Chamber thoroughly analysed the position of the Respondent, which considered that only 3 monthly salaries had not been paid to the Claimant and that further expenses should be deducted. In this context, the Chamber turned its attention to the said expenses, as pointed out by the Respondent.
17. First, the Chamber noted the Respondent’s argument that the parties agreed upon the payment of EUR 500 per month for the Claimant’s apartment. In this respect, the Chamber was eager to emphasise that the contract clearly stipulated that the Respondent will provide a “suitable accommodation”. The Chamber further noted that in its reply, the Respondent stated that a “normal apartment” costs between EUR 750 and EUR 800. Therefore, in the absence of any monetary value in the contractual condition relating to an apartment and of any documentary evidence in this connection (cf. art. 12 par. 3 of the Procedural Rules), the Chamber decided that the deduction of said expense by the Respondent is not valid.
18. In continuation, the Chamber considered that the Respondent was responsible for the payment of the water and electricity bills, as these costs are intrinsically related to the accommodation provided to the Claimant. As such, the Chamber was of the opinion that the deduction of such costs from the Claimant’s salaries, as argued by the Respondent, is not valid.
19. With regard to the costs of repair of the car, the Chamber took note of the Respondent’s argument that the Claimant was involved in two traffic accidents. In this regard, the Chamber observed the Respondent’s comments that it has obtained “an accurate quotation of costs”, however that “the Club has not repaired the vehicle which is why it does not have any receipts of such in possession”. In this context, the Chamber deemed that since the car has not yet been repaired, the Claimant cannot be held liable to pay potential costs which have not yet occurred. Moreover, in relation to the traffic fines allegedly imposed on the Claimant, the Chamber considered that although these costs could in principle be borne by the Claimant, the Respondent could not deduct said amounts from the Claimant’s salary.
20. Finally, as regards the social security contributions from January to December 2019 as invoked by the Respondent and amounting to EUR 1,832.67, the Chamber noted that the contract stipulated that “taxes [are] to be paid according to Maltese law”. However, the Chamber further observed that the contract does not mention who shall pay said taxes and does not stipulate whether the amounts are to be considered net or gross. In light of the foregoing, the Chamber concluded that in accordance with the jurisprudence of the DRC, it shall be assumed that the amounts are to be paid as net.
21. In view of all the above and based on the information and documentation on file, the members of the Chamber agreed that the arguments put forward by the Respondent to justify the deduction of expenses from the salaries of the Claimant cannot be accepted as valid.
22. Therefore, the members of the DRC highlighted that, at the moment the Claimant terminated the contract, 4 monthly salaries remained outstanding. In these circumstances, the Chamber considered that the Claimant could have legitimately lost faith in the ability and will of the Respondent to fulfill its contractual obligation in due course.
23. Consequently, and considering the situation of the player at the time of termination, the Chamber was of the opinion that the objective circumstances at the time did provide the Claimant with just cause to terminate the employment contract.
24. In light of all of the aforementioned considerations, the DRC came to the conclusion that the Claimant had terminated the contract on 1 January 2020, with just cause.
25. Having established that the Respondent is to be held liable for the early termination of the employment contract, the Chamber focused its attention on the consequence of such termination. Taking into consideration art. 17 par. 1 of the Regulations, the Chamber decided that the Claimant is entitled to receive from the Respondent an amount of money as compensation for breach of contract in addition to any outstanding payments on the basis of the relevant employment contract.
26. First of all, the Chamber reverted to the Claimant’s claim in which he requested the amounts of EUR 12,000 as outstanding remuneration, EUR 12,000 as compensation for breach of contract and EUR 9,000 as additional compensation.
27. In this regard, the Chamber considered relevant to recall that the months of September, October, November and December 2019 were outstanding in full. Consequently, taking into account that the contract was terminated on 1 January 2020, and in accordance with the general legal principle of pacta sunt servanda, the Chamber decided that the Respondent is liable to pay the Claimant the amount of EUR 12,000.
28. In addition, taking into account the Claimant’s request as well as the constant practice of the Dispute Resolution Chamber in this regard, the Chamber decided that the Respondent must pay to the Claimant interest of 5% p.a. on the total amount of outstanding remuneration, i.e. EUR 12.000, as of the due dates until the date of effective payment, as follows:
5% interest p.a. on the amount of 3,000 as from 1 October 2019;
5% interest p.a. on the amount of 3,000 as from 1 November 2019;
5% interest p.a. on the amount of 3,000 as from 1 December 2019;
5% interest p.a. on the amount of 3,000 as from 1 January 2020.
29. In continuation, 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 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.
30. In application of the relevant provision, the Chamber held that it first of all had to clarify as to whether the pertinent contract contained 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 regard, the Chamber established that the contract did not contain such a provision.
31. As a consequence, 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 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.
32. Bearing in mind the foregoing as well as the claim of the Claimant, the Chamber proceeded with the calculation of the monies payable to the Claimant under the terms of the contract until its term, i.e. the end of the season 2019/2020. According to the information available on the TMS, the 2019/2020 season in Malta would have ended on 8 June 2020. In this regard, the Chamber noted that the Claimant, in his claim, stated that the respective season ran from 23 August 2019 until 24 April 2020 and thus limited his request for compensation until the month of April 2020.
33. Consequently, the Chamber concluded that the amount of EUR 12,000 (i.e. salaries of January to April 2020) serve as basis for the determination of the amount of compensation for breach of contract.
34. 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 able 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. In this context, the Chamber noted that the Claimant had signed an employment contract with the Maltese club, Gzira United FC, valid as from 8 January 2020 for two seasons, by means of which he was entitled to a monthly remuneration of EUR 850.
36. The DRC thus noted that for the overlapping period, the Claimant had been able to mitigate his damages in the amount of EUR 3,400.
37. Therefore, the Chamber decided that the mitigated compensation due to the Claimant was EUR 8,600.
38. Moreover, taking into account art. 17 par.1 (ii), the DRC recalled that it had found that the player had unilaterally terminated the contract due to overdue payables and took note that the player had been able to mitigate his damages. Consequently, the Chamber decided that on top of the mitigated compensation, the Claimant should in principle be entitled to an additional compensation in the amount of EUR 9,000 corresponding to the equivalent of 3 monthly salaries.
39. This being said, the Chamber recalled that pursuant to art. 17 par. 1 (ii), the “overall compensation may never exceed the rest value of the prematurely terminated contract.” Considering the residual value of the contract in the amount of EUR 12,000 (cf. point II. 33.), the members of the Chamber emphasised that the additional compensation due to the Claimant may not exceed said amount.
40. Consequently, on account of all of the above-mentioned considerations and the specificities of the case at hand, the Chamber decided that the Respondent must pay the total amount of EUR 12,000 to the Claimant, which was considered reasonable and proportionate as compensation for breach of contract in the case at hand.
41. In addition, taking into account the Claimant’s request as well as the constant practice of the Dispute Resolution Chamber in this regard, the Chamber decided that the Respondent must pay to the Claimant interest of 5% p.a. on the total amount of compensation, i.e. EUR 12,000, as of 8 January 2020 until the date of effective payment.
42. Furthermore, the DRC 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.
43. In this regard, the DRC 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.
44. Therefore, bearing in mind the above, the DRC decided that, in the event that the Respondent does not pay the amount 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.
45. Finally, the DRC recalled that the above-mentioned ban will be lifted immediately and prior to its complete serving upon payment of the due amount, in accordance with art. 24bis par. 3 of the Regulations.
46. The Dispute Resolution Chamber concluded its deliberations in the present matter by establishing that any further request filed by the Claimant is rejected.
III. Decision of the Dispute Resolution Chamber
1. The claim of the Claimant, Wilfried Joselin Sabaly Domoraud, is admissible.
2. The claim of the Claimant is partially accepted.
3. The Respondent, Hamrun Spartan FC, has to pay to the Claimant the amount of EUR 12,000, plus 5% interest p.a. until the date of effective payment as follows:
a. 5% interest p.a. on the amount of 3,000 as from 1 October 2019;
b. 5% interest p.a. on the amount of 3,000 as from 1 November 2019;
c. 5% interest p.a. on the amount of 3,000 as from 1 December 2019;
d. 5% interest p.a. on the amount of 3,000 as from 1 January 2020.
4. The Respondent has to pay to the Claimant compensation for breach of contract in the amount of EUR 12,000, plus 5% interest p.a. as from 8 January 2020 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.
*****
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 appeal procedure:
According to article 58 par. 1 of the FIFA Statutes, this decision may be appealed against before the Court of Arbitration for Sport (CAS). The statement of appeal must be sent to the CAS directly within 21 days of receipt of notification of this decision and shall contain all the elements in accordance with point 2 of the directives issued by the CAS. Within another 10 days following the expiry of the time limit for filing the statement of appeal, the appellant shall file a brief stating the facts and legal arguments giving rise to the appeal with the CAS.
The full address and contact numbers of the CAS are the following:
Court of Arbitration for Sport
Avenue de Beaumont 2
1012 Lausanne
Switzerland
Tel: +41 21 613 50 00
Fax: +41 21 613 50 01
e-mail: info@tas-cas.org
For the Dispute Resolution Chamber:
Emilio García Silvero
Chief Legal & Compliance Officer