Action plans
The seven partner countries of the MotivAction project all have conducted studies and held focus groups with coaches, referees, and athletes to understand the current situation of whistleblowing in their countries. These consultations led to a comprehensive panorama of how each country’s sports organisations deal with whistleblowing, how much countries are more or less vulnerable to match-fixing, and what the most important problems they face that encourages match-fixing or deters sports stakeholders to report fixed matches or attempts of match-fixing.
Bulgarian Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Match-fixing in Bulgaria is widespread according to Bulgarian sport stakeholders. However, the country has adopted laws to fight match-fixing and support whistleblowers in sport. Law n°60 of 2011 of the criminal code establishes the concept of crimes against sport, punishing criminals who took action to manipulate a sporting event. In 2005 Bulgaria passed a law in 2005 protecting any person reporting on a criminal activity, which can apply to match-fixing.
Sport stakeholders in Bulgaria think that whistleblowing in Bulgarian sport is mostly impaired by the lack of a clear procedure and of a defined reporting platform. They do not know to whom they must report the manipulation. Furthermore, they stated that the main reason pushing them or their colleagues to resort to manipulating a competition was low salaries.
For this reason, Bulgaria’s action plan consists in creating a reporting multi-sports platform to gather the reports of sports stakeholders, anonymously if the reporting person wishes it. Bulgaria will do efficient communication to inform sport stakeholders of the existence of this platform. The action plan also consists in spreading awareness on match-fixing and on the necessity of whistleblowing by publishing a handbook for sports stakeholders. This handbook would give clear instructions regarding the procedure to report an attempt of manipulation in sport. The Bulgarian National Platform on the fight against the manipulation of competitions also wants to develop a closer cooperation with betting operators to monitor the competitions. Lastly, Bulgaria’s legislation should allow the Bulgarian National Platform to prohibit betting on suspicious competitions.
Cyprus Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Match fixing in Cyprus is widespread according to Cypriot sport stakeholders. However, the country has adopted laws to fight match-fixing and support whistleblowers in sport. The law on the fight against the manipulation of Sports Events n°180(I)/2017 establishes the National Platform against the manipulation of sports competitions (the Committee of Ethics and Protection of Sport), which investigates on manipulation reports. Cyprus also adapted the European directive on the “Protection of Persons Reporting violations of the EU and National Law 2022” in its national law. It provides whistleblowers with police protection and ensures that they remain anonymous throughout the investigation. It also makes mandatory for every organisation with 50 employees or more to have a reporting mechanism.
Low salaries are there again the main reason why sport stakeholders in Cyprus resort to match-fixing. They are reluctant to report manipulation attempts and corruption in their sports due to a lack of trust in law enforcement agents and due to fear of reprisals, since denouncing a superior or a colleague can be detrimental to the whistleblower’s career.
Cyprus’s action plan will consist in the creation of a reporting channel for sport stakeholders in the country. This multi-sport reporting channel would be independent from clubs and sports organisations and would guarantee anonymity to the whistleblowers. There again, Cyprus’s government will communicate on this new platform and on the correct way to report a manipulation. The Committee of Ethics and Protection of Sport also advocates for an increase of its budget since it currently lacks means to lead its investigations.
French Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Corruption is not so widespread in French sport. Most French athletes want to defend the integrity of their discipline. However, no country is spared by match-fixing, both betting-related and sport-related. France has an important set of laws regulating match-fixing and whistleblowing. For example, law n°2010-476 on “opening to competition and the regulation of the gambling sector” regulates betting on sport competitions, while law n°2022-296 aiming at “democratising French sport” officially established the National Platform against the manipulation of competitions, which had been created in 2016. Two laws protect whistleblowers: law n°2016-1961 on “transparency, corruption and the modernisation of economic life” and law 2022-401 for “improving the protection of whistleblowers”.
Corruption may not be widespread in French sport, but sport stakeholders think that there are still obstacles to whistleblowing in France. The main obstacle that discourages French players from reporting manipulation attempts is the fear of reprisals, since denouncing a colleague in the world of sport is still frowned upon. An athlete who dares to speak up about a manipulation attempt may become an outcast in his club or federation and his career is therefore put at risk. Another obstacle is the fact that a report is sometimes insufficient to start an investigation. It must go along with evidence of match-fixing. For this reason, French athletes rarely report the match-fixing attempts they witness, knowing that their testimony will not actually lead to an investigation. Lastly, French sport stakeholders are not informed of the existing reporting system called “Signale !” and do not trust their integrity delegates.
The French action plan consists in improving the “Signale !” reporting platform. Its interface will be changed to provide its users with clear information about their rights, notably on their right to anonymity, to a police protection, as well as a statement reminding them that any retaliation against a whistleblower is condemnable. It will also be better advertised towards athletes, coaches, and referees. The lack of trust in integrity delegates is also concerning and will be addressed. France will also lead awareness raising campaigns more often, aiming at a younger audience.
Greek Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Sport stakeholders admitted that match-fixing was widespread in Greece, going as far as to call it a “structural problem”. Some laws tackle the issue of crime in sports, such as Sports Law 2725/1999, which condemns active and passive bribery and explicitly establishes match-fixing as a criminal offence. Greece also adapted the European directive on the “Protection of Persons Reporting violations of the EU and National Law 2022” in its national law. It makes mandatory for every organisation with 50 employees or more to have a reporting mechanism. Greece ratified the Macolin Convention in 2020 and therefore established the National Platform against the manipulation of sports competitions called Epathla.
Greek athletes rarely report manipulations of competitions because they do not know of a clear procedure to do so, nor do they know to which structure they can talk to. They think that their report will not lead to any significant investigation because of a lack of proof, and lastly, they are afraid of retaliation. An athlete who dares to speak up about a manipulation attempt may become an outcast in his club or federation and his career is therefore put at risk. This fear is reinforced by the fact that, as the Greek football federation acknowledged, it is currently impossible to guarantee the physical security of whistleblowers.
The Greek action plan consists in improving Epathla’s education campaign in order for it to reach a wider audience. It will also consist in encouraging public figures (Presidents of federations, political figures) to take a strong position against the manipulation of sport competitions. Greece also wants to develop an ambitious policy for the protection of whistleblowers. It will develop its own independent reporting channel. This reporting channel would remind the rights of the whistleblower and provide them with a security guarantee. Greece will also try to create several “integrity delegates” positions in the most important sports federations. These delegates would be contact points between the Epathla, the law enforcement agents and sport stakeholders on integrity issues.
Moldovan Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Match-fixing is widespread in Moldova. The country added two articles to its criminal code dealing with match-fixing: art 2421 “Manipulation of an event” and 2422 “Fixed bets”. It also passed a few laws regarding the protection of whistleblowers: law n°122 of 2018 on “the protection of integrity whistleblowers”; and law n°105 of 2008 regarding the “protection of witnesses and other participants in the criminal process”. The Moldovan National Platform for the fight against manipulation of competitions is managed by the National Anti-Doping Agency (ANAD). The ANAD developed a reporting channel on its website: the “Speak-up” button.
Moldovan sport stakeholders deplore the lack of reporting mechanisms and the lack of efficiency of existing ones. Moldovan sport stakeholders rarely report when they are approached to manipulate a competition or when they witness an approach. As in other countries, they think that reporting is pointless because it oftentimes does not lead to a proper investigation. They also do not trust the authorities they are meant to report to, since they are not independent from their clubs or federations. The fear of reprisal is also a reason why sport stakeholders are reluctant to report irregularities. Low salaries of sport stakeholders in Moldova is a problem as well since they encourage them to accept bribes.
Moldova’s action plan consists in the nomination of integrity delegates in the most prominent Moldovan Sports Federations, namely the basketball federation, the football federation, the tennis federation, and the table-tennis federation. Moldova also wishes to create an “integrity community” composed of two football players, one coach, one umpire, and one table-tennis referee, whose mission would be to analyse manipulation cases and think of ways to respond to them. The Moldovan National Platform will also lead awareness-raising campaigns and will train the aforementioned integrity delegates. It will promote the use of the “Speak-up” button on the ANAD’s website. Furthermore, the Moldovan National Platform’s organisation needs to be improved. It therefore asked for the assistance of the Group of Copenhagen within the ACT Project to further develop its capacities.
Polish Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Polish sport stakeholders think that Poland does not have a significant match-fixing problem. However, according to the company Sportradar, match-fixing is frequent in Poland. An Act on Sport was adopted in June 2010 providing for criminal liability for crimes against the principles of fair sports competition, which criminalises all forms of corruption in sport. Poland signed the Macolin Convention in 2015 and accordingly created its own National Platform: the Operational Group. Only one Polish law deals with whistleblowers: art 60 of the criminal code provides for a limitation of criminal liability for a person who, while cooperating in a crime, has disclosed relevant information about the aforementioned crime to law-enforcements.
Information about the match-fixing situation in Poland are unclear. According to its sport stakeholders, Poland does not have a significant match-fixing problem, and its athletes do not bet on competitions they could influence. However, according to the company Sportradar, match-fixing in Poland is frequent, and players do bet on their own matches according to referees.
Poland’s action plan will be to develop a system for safe reporting for whistleblowers. It will lead awareness-raising campaigns aimed at sport stakeholders on match-fixing and on betting as an athlete. Poland also wants to develop a platform for Polish betting operators to improve their cooperation with regulation authorities and law enforcement. Finally, Poland wishes to pass a bill that would allow the Operational Group to block winnings on suspicious bets.
Portuguese Action Plan
Cycle 1 - Sept 2022 > Sept 2023
Match-fixing seems to be quite widespread in Portugal. The country adopted the law n°50/2007 “on criminal responsibility for conducts that may affect the truth, loyalty and correctness of the competition and its results in sporting activity”, which criminalises passive and active corruption, as well as influence peddling and illegal betting. However, Portugal does not have any law on the status and protection of whistleblowers. The country has signed and ratified the Macolin Convention in 2015 but still has to create its National Platform on the fight against the manipulation of competitions. It does not have any multi-sport reporting channel either.
Match-fixing is widespread in Portugal and the country does not have the required tools to tackle this phenomenon. It does not have a National Platform, nor does it have laws for whistleblower protections, nor does it have a reporting channel by which sport stakeholders could report irregularities. Athletes do not trust the authorities they are meant to report to. They call for the creation of an independent whistleblowing system that would allow for safe and anonymous reports. Portugal needs to decide which organisation its National Platform will adopt. It is interested in reproducing the “Sport list” system from the French National Gambling Authority (ANJ) which clearly specifies which competitions are open to bets at the national level.
Portugal presented its action plan: It first wishes to decide of the organisation of its National Platform in order to formally establish it. It will in this end ask for the support of the Group of Copenhagen. Moreover, it will standardise its existing “Sport list” by following the organisation of the French one. The sport stakeholders’ aspirations do not seem to have been taken into consideration.