Introduction to this document
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Introduction to this document
How NFF has approached the 26 initiatives
On June 1st, a working group within the Norwegian Football Federation (NFF) administration was tasked
with starting up the work to meet the demands put forth in the Qatar report. This work is firmly anchored in
NFF’s administration and daily responsibilities. Anders Hasselgård is head of the working group and Iselin
Shaw of Tordarroch has been hired full-time to work with the follow up of the Qatar-related initiatives.
The group consists of 5 members, all with relevant backgrounds:
• Lise Klaveness, Technical Director
• Nils Fisketjønn, Director of Competition
• Anders Hasselgård, Head of International Social Responsibility
• Martha Lande, Senior Advisor Competition
• Iselin Shaw of Tordarroch, Advisor International Social Responsibility (since August 2 nd)
The first step for the group was to get a clear picture of the current situation for all areas touched by the
initiatives, as well as the stakeholders involved. This was obtained first by going through the existing
reports from the main stakeholders (Norwegian Qatar Committee (NQC), FIFA, Supreme Committee
(SC), Building and Wood Worker’s International (BWI), Amnesty, listening to recordings of the previous
FIFA plenum meetings which included all major stakeholders (Amnesty, BWI, SC, and the International
Labour Organization (ILO)), and through meetings with FIFA, Amnesty and BWI/ United Federation of
Trade Unions [Fellesforbundet]. The working group also consulted with human rights lawyer, Pia Goyer,
(member of the NQC), to better understand some of the information obtained. As soon as an acceptable
knowledge base was established, the working group continued with regular meetings with both FIFA, BWI
and other relevant stakeholders throughout the following months.
Interaction with FIFA
The working group has met with FIFA five times between June and September (June 10th, June 16th,
June 21st, July 9th, September 16th).
The aims for the meetings with FIFA have been to:
• Obtain detailed information about and understanding of FIFA’s work, plans, and position on
relevant issues
• Clearly communicate to FIFA the demands and expectations of the NFF general assembly
• Find common ground and areas where NFF can help move processes along
• Understand the political situation, in order to settle on the strategically best approach
• Push FIFA in the desired direction through dialogue with pressure
This approach follows the recommendation from the NQC report: that NFF continue the dialogue line in
its work to achieve the goals of the 26 initiatives.
1FIFA has participated in the meetings with 4 persons: Andreas Graf (Head of Human Rights & Anti-
Discrimination), Nodar Akhalkatsi (Director of Executive Office General Secretary), Joyce Cook (Chief
Education and Social Responsibility Officer) and Alessandro Gramaglia (Development Programs
Manager).
By July, the group had built up an acceptable knowledge base, and could, through the following meetings
with FIFA, be more precise when engaging in discussions, and thus also exert more pressure through
dialogue. The attention on football and human rights that was gained through both the boycott discussion
and the activism from the national teams, made NFF a relevant stakeholder in questions regarding the
situation in Qatar and general human rights questions for the football world. NFF has attempted to use
this momentum to set the agenda for the future approach and discussions on the topic.
FIFA has met the questions and the pressure from NFF with openness, and all questions from NFF have
been answered without reservations. Several representatives from FIFA also followed the extraordinary
general assembly all the way through with the assistance of translators. It is worth noting that FIFA has
already initiated a few changes independent of the process in NFF. These changes are in line with the
demands and initiatives from the NFF extraordinary general assembly.
NFF is in continuous dialogue with FIFA, and still has several follow-up questions with regards to
previously discussed issues. As the questions and issues accumulate, NFF contacts FIFA for new
meetings to discuss these issues, as well as the reports from independent human rights organizations.
NFF is taking a clear position on what is expected from FIFA and the football community in relation to the
various findings in line with the resolution from the extraordinary general assembly.
Interaction with independent organizations
Throughout the last few months, NFF has met with both Amnesty and BWI several times. In the meetings
with Amnesty NFF has been able to get an independent description of the situation in Qatar, and to set up
lines of communication in case of serious new incidents that should be reacted to by NFF. BWI has also
been a valuable partner in describing the situation on the ground, the political field, as well as a report on
progress and discussion of priorities. In addition to being a valuable source of information, BWI is also
especially important as they are the initiator of the proposed center for migrant workers, and close
cooperation with BWI is essential for NFF to be able to meet the demands of the 26 initiatives. NFF
receives any new reports directly from the various organizations.
NFF has also met with the Business & Human Rights Resource center (BHRRC) after the publication of
their report on human and labor rights in a selection of luxury hotels in Qatar, which uncovered multiple
concerning breaches. NFF’s work with the hospitality sector is in line with the recommendations put forth
in their report and during the meeting in September 2021. A specific example of NFF’s plans in response
to the BHRRC report is to put together a due diligence guideline that we welcome other football
federations and interested parties to use as part of their own due diligence.
2The UEFA Human Rights group
UEFA has appointed a Working Group on Human and Labor Rights, with the following mandate:
The aim of the working group is to provide commitment and leadership to ensure the respect of Human
Rights, and specifically Labor Rights, related to the 2022 World Cup Qatar. Its aim is to represent all our
55 member associations as a focal point and to ensure a coordinated approach. All the next steps and
concrete actions will involve FIFA as the organizer of the event. The working group will regularly inform all
our member associations through the UEFA NA GS meeting channel. The objective is also to ensure a
permanent and strong legacy in Qatar post 2022 and to guarantee a human rights policy for the future
UEFA events. The working group will be accountable for:
1. The development of a Human Rights risk assessment and a track of the improvements and
changes in the law.
2. The creation of a monitoring plan of the HR processes/progresses in Qatar.
3. The involvement of independent Global Institutions.
4. To ensure communication to all 55 member associations, stakeholders and media.
5. To prepare the final report.
The creation of this group has likely been caused by the attention that has been drawn to human rights
questions in football, in part by the aforementioned Norwegian movement. Norway has obtained a seat in
this group, which consists of representatives from 8 European countries. This group is using the findings
from the NQC, including the 26 initiatives, as well as the knowledge base gathered by the current NFF
working group, as part of their work. At the present moment NFF considers it strategically wise to
coordinate their efforts with other European federations through the UEFA group, in order to have a
stronger voice and more power behind demands. Thus, the continued work on many of the initiatives will
be aligned with UEFA in the coming period. However, it is important to be aware that this will only be the
case for as long as NFF considers this approach to be the best option for achieving change. If the UEFA
group chooses a different direction from what is proposed by the NQC, NFF will stand by the initiatives as
decided by the general assembly and move along with the work on its own.
The UEFA group has so far met formally three times, and recently also completed a trip to Qatar to meet
with relevant stakeholders. This trip was in line with the Norwegian initiatives and dialogue line, and in
Qatar much focus was put on the planned migrant center and how to ensure practical implementation of
the recent legal reforms in Qatar. NFF was able to gain an even deeper insight into the situations and
challenges faced. The NFF administration and the UEFA group are now looking to evaluate the situation
based on the information and discussions in Qatar, to decide how to best move forward, independently or
as a group. Norway is the only participating nation who also has a role in the secretariat headed by
UEFA’s Diversity & Inclusion department. The secretariat has met several time since the creation of the
working group.
NFF has welcomed UEFA and other federations to use the work done by the NQC and the follow-up done
by the NFF administration to themselves have an easier path on their own journey towards structuring the
work for human rights.
3The structure of the list of 26 initiatives
Below is a summary of all the initiatives suggested by the NQC and passed by the extraordinary general
assembly. It includes the wording of the initiative, as set forth in the NQC Report (English version), as well
as our own summary of the current situation and an evaluation of progress since the Qatar report.
The description of the current situation is NFF’s own and is attempted to be as factual as possible. The
understanding is based on the collective work completed since June 1st. The progress report attempts to
describe as accurately as possible what concrete actions NFF has taken with regards to the specific
initiative, and what, if anything, has been achieved. Action points can be found at the end of the
document and describe some of the main steps for NFF and other actors in the coming working phase.
For the purpose of this document, the initiatives have been reorganized from their original grouping
(Human Rights, Sports Washing, Governance) into groups based on workflow logic (what bodies are
addressed, who are our partners etc.)
• Initiatives concerning the situation in Qatar.
• Initiatives aimed at FIFA’s structure, rules and regulations.
• Initiatives aimed at UEFA’s structure, rules and regulations.
• Initiatives asking for cooperation with national and international organizations.
• Initiatives aimed at NFF’s own procedures, structure, strategy, rules and regulations.
INITIATIVES CONCERNING THE SITUATION IN QATAR
Initiative NFF should immediately contact FIFA when it learns of serious new
incidents in Qatar, to request that FIFA exerts its influence with the
Supreme Committee and the authorities in Qatar to achieve the fastest
possible change.
Progress report One of the issues identified initially was that NFF would learn about incidents
relatively late, and through the regular media. It was desirable to design a
system where NFF would be alerted at an early stage. NFF contacted Amnesty
and BWI to discuss and organize internally the best way to accomplish this.
NFF has now implemented a system to be able to respond to human rights
events occurring in Qatar. NFF should now receive an alert from relevant
organizations in cases of serious incidents in Qatar.
Three situations have surfaced since the system was implemented. NFF has
discussed three identified serious issues with FIFA; The Human Rights and
Business Resource Center report on luxury hotels in Qatar, The Amnesty
report on deaths among migrant workers in Qatar, and the verdict in the
Malcolm Bidali case. All three have demonstrated the effectiveness of the
system in place to ensure that NFF is alerted when incidents occur.
Overall, FIFA is glad that NFF is raising important issues and have been open
in their response to NFF’s questions on the topics.
4Current situation NFF monitors the media and social media channels for information about the
situation in Qatar. In the case of an incident, relevant personnel in the
administration do an analysis of the situation, and a response is issued through
social and regular media, depending on the situation.
FIFA also informs that they already have an extensive system in place to get
reports from the ground through independent organizations. They learn about
issues through the following:
• FIFA’s own monitoring systems on the ground
• Impactt Ltd.’s independent monitoring (ethical trade consultancy)
• Grievance mechanisms for workers, journalists, and human rights
defenders
• Regular engagements with non-governmental organizations (NGOs),
the ILO and other entities
• Information through investigations by journalists
FIFA confirms they also do work through the higher political channels to
implement change. For the abolishment of the Kafala system, FIFA contributed
to the wider effort through political discussions.
Initiative NFF should demand that FIFA issues quarterly reports to all football
associations about the preparations for the competition, with clear
performance indicators.
Progress report This issue was high on the agenda for the first meetings with FIFA, as it is hard
to keep track of progress without regular and easily accessible reporting. FIFA
informed NFF that they are developing a website, which will include regular
updates on progress in Qatar. Upon learning about the planned reporting
website, NFF offered support in developing, methodology and design in an
effort to both speed up the process and ensure high quality. FIFA declined the
offer of assistance on the website, but welcomes input from NFF on what
indicators should be included, and feedback on the general user experience. If
the website is launched and is informative and up to date, this is a big
improvement. NFF will need to see the website and how it is updated before
considering whether any further demands are required to fulfil the intention of
the initiative.
5Current situation FIFA plans to launch the website by mid-October. The website will replace the
progress reports in that it provides regular updates against the 79 initiatives of
the. Every initiative includes at least one key performance indicator (KPI) to
quantify progress.
The SC regularly releases public progress reports providing details on the SC’s
activities, and the successes, challenges and upcoming priorities relating to its
Workers’ Welfare Program and can be found on the existing FIFA website.
For quantitative indicators on initiatives that are about ongoing risks, in
particular in relation to workers’ rights, FIFA points to the Impactt Ltd. reports
and the worker surveys, as well as the BWI reports.
Initiative NFF should ask FIFA to engage with the authorities in Qatar to secure the
establishment of enhanced inspection mechanisms to enable abuses
against workers to be quickly uncovered and stopped.
Progress evaluation NFF has through meetings with both FIFA and BWI attempted to investigate
further as to what exactly is required to raise the level up to an acceptable
level. The understanding is that the inspections themselves are of good quality,
and serve their purpose, but that they have not covered all relevant sectors.
NFF raised the concern about the hospitality and service sector with FIFA, and
asked for more details regarding the work ahead. When learning about the
plans for the next phase, NFF expressed the need for urgency in this matter,
and also offered to contribute to the effort, for example by funding independent
inspectors or relevant experts. NFF has read the independent report from the
Business and Human Rights Resource Center with dismay, and FIFA shares
this concern. FIFA has done initial audit of 15 hotels and have hired inspectors
to be on the ground from October 1st to expand their audits also to hotels. NFF
has also met with BHRRC for input on how best to proceed to improve the
situation. Their foremost recommendation was for NFF to establish a guideline
for due diligence. NFF will also continue its dialogue with BHRRC.
NFF is looking to ensure good due diligence processes by coordinating through
UEFA and is prepared to take a leading role in this work. NFF hopes the result
will be a due diligence policy document available and applicable to all
European FAs. This initiative needs special attention over the next period, and
is high on the NFF agenda.
6Current situation Within the building sector, the inspection mechanisms are in place, and have
shown to contribute to improvement when it comes to workers’ health and
rights, especially for the WC infrastructure sites. However, there is still a long
way to go to raise the overall standard in Qatar. There is also a dire need for
implementation of the same system in other sectors, especially the hospitality
and service sector.
One of the main issues that has been highly debated worldwide is the
shockingly high number of deaths among guest workers working on the WC
construction sites. It has later been revealed that this number covers all guest
worker deaths in Qatar since Qatar won the hosting rights, including non-work-
related deaths and deaths at non-World Cup related sites. FIFA informs that
since construction began in 2014, there have been three work-related fatalities
on FIFA World Cup sites and 35 non-work-related deaths amongst FIFA World
Cup workers. Any serious accidents – including those without fatal
consequences - are investigated by a team of experts at the SC. Since 2018,
the procedures for investigations of work-related fatalities have also included
experts from BWI to ensure independence, transparency, and the best possible
learnings from such accidents for the companies concerned and the SC’s
oversight mechanisms. However, in a recent report Amnesty challenges what
is defined as a work-related fatality or not, and thus what deaths are being
investigated.
With respect to wider health and safety reforms within the country, FIFA meets
regularly with the relevant authorities and, in particular, closely monitors the
work of both the Ministry of Labor and the ILO Office in Doha, including with
respect to the ILO’s upcoming report on occupational injuries.
Worker-related due diligence systems have been put in place on World Cup
sites. These mechanisms include, for example, occupational health and safety
measures on site, comprehensive medical checks of all workers, as well as
projects to address other potential causes of health hazards, such as heat,
nutrition, mental health, or Covid-19. In addition, regular independent
inspections are carried out by BWI, and the specialized labor rights
consultancy, Impactt Ltd. FIFA has had European inspectors on the ground,
and has received feedback that the health, safety and environment (HSE)
standards at the World Cup sites are very high.
BWI expresses that they find the work of the SC satisfactory. “The SC
implements a four-tier auditing system against the Worker’s Welfare Standards,
comprised of contractors’ self-audits (first party), comprehensive SC audits and
inspections (second party), external monitor audits (third party), and ad hoc
inspections conducted by the Ministry of Administrative Development, Labor
and Social Affairs (MOADLSA). The SC’s audit and inspection regime is
complemented by joint health and safety inspections conducted by the SC and
7BWI. In addition, the SC carries out health, safety and security inspections on a
revolving monthly plan” (BWI report).
FIFA is working closely with the SC, who again is responsible for carrying out
the inspections. FIFA considers that their role in this is to ensure that SC is
taking their responsibility seriously. FIFA finds that SC is doing a good job in
Qatar. BWI have access in Qatar, and decide where to go for their inspections.
They can raise issues directly to FIFA if they find that the SC is limiting their
access or otherwise not doing what they promise. FIFA describes the situation
as very different from Russia 2018, where FIFA themselves had to do the
inspections, as they experienced that the organizer could not be trusted. If
FIFA believed that the SC would not do the job properly, they would be more
directly involved.
However, the focus is now shifting towards the service and hospitality sector.
The BHRRC report mentioned already paints a grim picture of the current
situation in the hotel sector when it comes to worker’s rights, saying that ‘[their]
research shows hotel brands have failed to take necessary action to protect
migrant workers, who suffer serious abuses including: extortionate recruitment
fees, discrimination and being trapped in a job through fear of reprisal and
intimidation’ (Checked out – Migrant worker abuse in Qatar’s World Cup luxury
hotels, Business & Human Rights Resource Center). As mentioned, due
diligence will be key to addressing the problems uncovered in the BHRRC
report. The minimum requirement for hotels in Qatar now is for them to provide
compliance and revision reports upon request by the customer.
FIFA and the SC are gearing up for implementation and inspections for the
service and hospitality sector. They have already conducted initial audits at 15
hotels and aim for the full inspections to start up in October. There will be a lot
of workers coming in, and for this sector there will also be a gender
perspective, and new possible problems (e.g., trafficking, sexual harassment)
for the workers. For this part FIFA plans to be more directly involved, and will
put a team of their own on the ground together with the SC team, as well as
include other organizations with specialized knowledge in the field. FIFA looks
to partner with Elevate for the audits of the inspections, and is also looking for a
relevant local organization in Qatar to help on the ground. More concrete
information regarding this will be communicated shortly.
FIFA and Q22 will audit all contracted hotels against the SC’s Workers’ Welfare
Standards. There will be no ranking or indicators showing level of compliance
for the hotels, but the hotels will share audit reports and compliance plans with
any football association asking for them, in order for the football associations to
do their own due diligence. There are no explicit minimum levels of compliance,
but FIFA will (and does) cancel service contracts with providers unwilling to
rectify in the compliance area.
8Initiative NFF should work to persuade FIFA to demand that the authorities in
Qatar improve migrant workers’ legal protection through mechanisms
that ensure abusive employers are held to account.
Progress report NFF’s understanding is that there has been significant progress over the last
couple of years when it comes to Qatar’s labor laws. The overall situation for
the workers, however, is not yet satisfactory, as the legal amendments are not
always sufficiently followed up in practice. NFF has asked for numbers on
breaches of labor laws, numbers on employers being persecuted through the
legal system and reporting on outcomes of such cases in the legal system, in
order to better understand the practical effectiveness of Qatar’s labor reforms.
As the initiative recognizes, the need now is to ensure continued adjustment,
and NFF believes this to be best supported through the continued support of
the actors working for labor reforms in Qatar, as well as making sure the public
eye does not disappear once the World Cup ends.
The Center for Migrant Workers, proposed by BWI, is an important step in
providing more long-term assistance for the workers, especially when it comes
to access to legal assistance. It will impact not only the workers related to the
World Cup, but also be a legacy for migrant workers in the future. Both NFF
and FIFA wish to put a lot of focus on this initiative, and to help it come to life.
The same goes for the UEFA working group. NFF was consistently encouraged
the UEFA working group to put the migrant center high on the priority list and
have achieved significant progress on this point.
9Current situation The most important measures introduced by the Qatari authorities since 2015:
• “The Domestic Workers Law”, which limits working hours and mandates daily
rest breaks, one day off a week and paid holiday.
• More than four workers are no longer permitted to be accommodated in the
same room.
• Labor Committees have been established to resolve work-related disputes
and increase workers’ protection under the law.
• The introduction of fines and prison sentences for the withholding of wages
(wage theft), as well as a fund to support and accelerate the payment of unpaid
wages.
• A non-discriminatory new minimum wage (implemented in 2021).
• The adoption of legislation to remove the most problematic and restrictive
aspects of the kafala system, including the requirement that workers obtain exit
permits and no-objection certificates if they wish to change to a new employer.
• Ratification of two key international human rights conventions, even though
Qatar has reserved the right to ignore some of their key obligations, including
the right of workers to form and join trade unions.
• The adoption of new legislation to ensure workers are better protected from
heat stress during the summer months
In terms of legal steps available against employers breaking the laws are
penalties, the use of blacklists, and removal of permits. The SC has taken
strong action against companies that are in clear breach of rules and
regulations. However, the goal is compliance rather than punishment. Some
companies want to improve, and the SC therefore does not put full force in
punishment unless a company clearly demonstrates a lack of willingness to
comply. The result is that some of the previous worst offenders now are the
best when it comes to compliance. For those not interested in compliance,
punishment is being used. The SC says it is possible to see publicly that there
is a shift in approach in Qatar. For example, there was a case with security
guards demonstrating, the SC looked at their work contracts and judged them
to be illegal due to clauses hindering mobility, and this was then broadcast in
the media.
Currently part of the problem with incidents such as Malcolm Bidali is that the
ministry of interior interferes using the state police and immigration authorities
with issues that should have been handled by the ministry of labor. It is a fear
that this part of the government will work to counter the reforms that have been
implemented, and thus such incidents may appear.
10Initiative NFF should demand that FIFA take an active role in helping to ensure that
workers engaged in the construction of stadiums and other World Cup-
related infrastructure in Qatar receive what they are entitled to. This
means, for example, that FIFA must be kept informed by the Supreme
Council of any non-conformances, and must follow up the Supreme
Committee’s activities with respect to the workers concerned.
Progress report NFF has asked for more information on numbers for World Cup infrastructure
workers waiting for their money, the average waiting time, and what FIFA/SC
are doing to ensure that workers get what they are entitled to. NFF has also
asked for this to be included in the new FIFA reporting website, and raised
concerns regarding the offboarding of workers from soon to be finished World
Cup infrastructure, especially if they have cases pending in the legal system.
NFF’s approach is to advocate for openness and transparency so that relevant
information is made available for accurate analysis of the situation.
Current situation One of the major concerns is the processing time for complaints. This is the
state system (not SC), and relevant in this situation, as the SC sometimes refer
workers to the state mechanism. There is also no system for treating cases
collectively, meaning identical cases (same employer, same issue) are treated
separately. This leads to long waiting times. An allowance to treat cases
collectively will speed up the processing of the cases. BWI also notes that it
should not be necessary to go to court with all grievances, it should be
sufficient to go to the ministry that has access to all the information (work
contracts, payments etc), but notes that the ministry does not have the
manpower to follow up on this. BWI states that 70% of the cases delayed are
regarding unpaid wages. The workers only stay for a couple of years, and need
a fast track to expedite the cases.
During NFF’s meeting with FIFA in September 2021, FIFA informed that they
have gone back a year to review trends on delayed wages and found none that
exceed two months of waiting in this period. The SC have relevant statistics
through the wage protection system but are not currently publishing these
numbers. At this point there are no cases in which salaries have been delayed
for more than two months at World Cup sites. FIFA guarantees that all workers
get their salaries in the end at FIFA structures and that their experience is that
all flagged cases are already on the SC’s radar or that the SC are able to
obtain full information within three days.
11Initiative NFF should challenge FIFA to take further steps to ensure respect for
workers’ right to unionize.
Progress report Working along the line of securing the right to unionize is currently considered
by NFF as unrealistic and somewhat counterproductive, as the work for
stronger organization does not follow the unionizing track. This understanding
is based on feedback from BWI/ILO, FIFA and human rights lawyer, Pia Goyer.
NFF acknowledges that the purpose of the initiative is to support organization
of workers and will therefore follow the lead of BWI/ILO in strengthening the
rights for workers through development of the current Work and Welfare forum
system, which is sorted under another initiative. NFF’s general priority is to
strengthen the worker’s voice in all relevant forums.
Current situation NFF’s understanding is that the full right to unionize is fairly unlikely to happen
in Qatar. Currently the International Trade Union Confederation and the ILO
are not considering the right to unionize as an immediate priority of their work.
Should that change, FIFA will support these efforts. The Workers’ Welfare
Forum system is the current system to ensure workers’ voices are heard and is
a system that has evolved. The SC initially created the Workers’ Welfare
forums to create a safe environment where workers could bring their
grievances without fear of retaliation. However, the SC saw that the
representatives were being appointed rather than elected, and the issues
brought forward were minor. The SC themselves explain that they understood
that this system was not working when they registered that no real grievances
were uncovered. In cooperation with BWI, the SC worked on developing the
Work and Welfare forums into more safe environments. Today 90 percent of
the workforce vote for their representatives. The system is not fool proof, and
even the SC points out that there are issues. The mandating of worker-
management committees is another important step in the right direction. This
may eventually create the foundation of more independent unions.
12Initiative Support the start-up of a resource center for migrant workers, which is
currently being established, by contributing initial capital. NFF should
strongly encourage FIFA to do the same.
Progress evaluation The migrant center has been high on the agenda for NFF in meetings with
FIFA, and the main focus in the meetings with BWI. NFF was initially ready to
go ahead with support and involvement. However, through the meetings it
became clear that the center had not moved past the idea stage, and there is a
need for specification of plans.
Whether such a center could be completely independent was challenged, and
discussion as to who should be partners in the center arose. NFF is aware of
recent talks between the major stakeholders, and is now waiting for feedback
on the current status.
FIFA has expressed support of the plans for the center, and is looking to move
the process forward, but points out that some basic political commitment in
Qatar needs to be in place. Meetings between SC/FIFA/BWI have been held
over the last couple of months. This center is a very important case in terms of
legacy. FIFA is looking to embed the decision regarding the center with the
Qatari authorities (in addition to SC) over the coming months.
BWI is looking to ask for a large lump sum of money instead of yearly support,
so that the interest can secure the running of the center, and will not be
dependent on continuous sponsorship. The hope is to launch the center at the
end of 2021/beginning 2022. BWI hopes for a public launch with ownership
from many groups and federations.
Considering this, it is too early for NFF to go ahead with capital. Support in
terms of interest, coordination between federations, and pressure is relevant in
this stage. NFF has taken a leading role in coordinating the efforts of the
European federations, and this will be done through the UEFA working group
for human rights. NFF has been successful in putting this initiative on the UEFA
group’s agenda and is confident that such a center will create significant
improvements for workers, their access to legal rights, before, during and after
the World Cup.
13Current situation The migrant workers need a safe place for workers to come to issue complaints
and get help. There have been deportations due to talking and advising on
legal laws. The main thing for the center is legal recognition, and legal
protection. This will mean that the workers at the center will need to be legally
protected, and the center should be recognized as a legal entity. It needs to be
an independent center, where the employees are not afraid, not controlled by
the SC or Qatari government. BWI believes that if many groups are involved in
the project, it is much harder for Qatar to pull the plug on the project after the
World Cup. If the center becomes a local institution, it will be easier to ensure
its long-term existence.
Initiative NFF shall ask FIFA to demand a guarantee from the authorities in Qatar
that members of the free press will be allowed to enter the country and
access the facilities before, during and after the World Cup. This is
particularly important to verify the quality of the information and follow-
up of conditions in the country, and involves easy access to a visa for
any journalist who wants one.
Progress evaluation FIFA has explained in meetings that such a guarantee has already been
obtained from Qatar. NFF has challenged FIFA on the topic, to gain insight into
whether such a guarantee could be considered legitimate. The Covid-situation
has complicated international travel, and thus also the ability to evaluate the
current situation. Until the World Cup is over the situation should be monitored.
Guarantees were also given by the Qatari authorities as part of the government
guarantees, and also in joint commitments outlined in the Sustainability
Strategy. The policy detailing event-time regulations on access and filming
permissions is currently being worked on.
14Current situation The few incidents with international journalists that have occurred so far have
been handled by SC and Qatari authorities. From an international journalist
perspective, FIFA is comfortable that everyone who is nominated by their
countries will gain access, and FIFA can also nominate journalists directly.
FIFA expects very few restrictions for journalists during their stay in Qatar.
FIFA reports that their current priorities include engagement with Qatari
authorities on the revision of the press freedom legislation, including through
the newly established Memorandum of Understanding with the Qatari National
Human Rights Committee, and the finalization of tournament-specific media
related policies and procedures.
FIFA mostly registers domestic issues, for example a situation where a NYT
article on LGBTQ+ rights was removed from the local edition, but when
investigated it was found that the editor had performed self-censorship. Qatar
has a new reform on the steps regarding freedom of press, which is expected
to be implemented later this year. This legislation will replace the outdated
legislation from the 1970s. FIFA has asked for more information about the new
legislation, and is awaiting this information.
On the grievance mechanisms, FIFA has an online system in place for
complaints. It exists in all FIFA languages, and you can submit complaints in
any language. This system is always active, but FIFA will also make an
individual system for each specific championship, aiming at broader groups
and topics. In Russia FIFA asked organizations like Amnesty to report to them
with grievances, but most grievances filed were already known to FIFA through
other channels. Regarding the current situation in Qatar, there were hundreds
of journalists going in and out of Qatar before Covid-19, and they confirmed
that Qatar is indeed open. Any journalist that experiences otherwise is
welcome to contact FIFA.
15Initiative NFF shall demand that the authorities in Qatar implement adequate
measures to ensure that members of the LGBTQ+ community feel
welcome and safe as participants or guests during the World Cup.
Progress report This issue has been discussed extensively in meetings with FIFA, and NFF has
also consulted with human rights lawyer, Pia Goyer, on the topic. NFF worries
that even though Qatar has expressed their clear intentions of welcoming
everyone, LGBTQ+ persons may still face difficulties during the tournament.
FIFA has had a stakeholder meeting with relevant organizations to create an
umbrella group with the primary objective being to provide feedback and input
to FIFA’s initiatives and additional guidance as appropriate. Hopefully they can
give a degree of reassurance to their groups of the safety of attending the
tournament and give FIFA relevant feedback and information. More about this:
FIFA World Cup 2022™ - News - International stakeholder group to support
ensuring an inclusive FIFA World Cup launched - FIFA.com
NFF will await the first feedback from the FIFA stakeholder group to hear their
evaluation of the situation, and continue to raise concerns and keep pressure
on the issue.
16Current situation Homosexuality is illegal in Qatar, but it is commonly understood that the law is
not being enforced.
FIFA is working to make the World Cup event safe for the LGBTQ+ community.
FIFA looks at this issue from three angles:
• People must be protected and safe when coming and staying in Qatar.
• Sexual orientation should not be a factor when people decide to go to
Qatar.
• Provide a platform for conversation for a wider change.
FIFA informs that they conduct training of their own staff, and engage with
organizations on the ground. The training with public security personnel is not
conducted by FIFA. It is conducted by a specially created Training Unit at the
SSOC, which is the entity responsible for the delivery of safety and security.
The SSOC is staffed with international experts on the topic. FIFA and Q22 are
providing expert review and support on human rights-related elements of the
training.
Inside stadiums there are systems in place for monitoring and follow-up.
17INITIATIVES AIMED AT FIFA’S STRATEGY, STRUCTURE, POLICIES, RULES AND REGULATIONS
Initiative NFF shall demand that FIFA incorporate a permanent, independent
human rights committee as a key part of the FIFA organisation, with
members nominated by internationally recognised human rights
organisations. In addition, a greater focus on independence is crucial in
connection with nominations to all independent bodies in FIFA.
Progress report This topic has been discussed extensively in meetings with FIFA. FIFA has,
based on the final conclusion from their own temporary Human Rights Advisory
Board, already decided to implement a Human Rights sub-committee in their
internal structure for work with human rights. Participation in the establishment
of the new sub-committee through nominating members is relevant, and NFF is
looking to shortly nominate a Norwegian expert as a representative, to ensure
a continued line from the NQC into the work of FIFA. NFF will also monitor the
process and development of the sub-committee and its mandate.
Current situation The members of FIFA’s new sub-committee consist of a combination of elected
members and some that are already members. Independent experts will also
form part of the sub-committee but will not go through nominations as their
appointment will be based on profile, expertise, and experience. Although the
new committee will look different from the suggestion in the initiative, NFF has
consulted with independent experts, and now believes the solution to be just as
good, or potentially better. The mandate for the sub-committee is not ready yet,
but the regulations should shortly be adopted. FIFA expect this to take place
within the next couple of months.
18Initiative Work actively to ensure FIFA establishes a system to ensure
transparency and independence in connection with nominations to all
independent bodies in FIFA.
Progress report FIFA themselves were impressed by the transparency and openness with
which the NFF extraordinary general assembly was conducted. NFF will work
through political channels in further advocating these important democratic
ideals in the international football democracy. A natural arena to discuss this
topic will be the UEFA human rights working group, and the FIFA Congress.
The plan for this should be secured in the NFF new long-term human rights
strategy, and will be included in the upcoming work in this area, but NFF will
also use any opportunity in the meantime to bring up the subject with relevant
parties.
Current situation The level of transparency in the FIFA model has been criticized over the last
few years. Transparency is a key element in functional democracy, and is
something which NFF will be more vigilant about in years to come.
Initiative NFF should become a member of the UN Global Compact and work for
FIFA to do the same.
Progress evaluation NFF became a member of the UN Global Compact (UNGC) in June 2021, and
the follow-up of the responsibilities that come with this membership now lies
within the NFF administration.
19Current situation In advance of NFF’s membership, UN Global Compact Norway conducted a
thorough assessment into whether a membership in UN Global Compact is
relevant and useful for sports organizations in general and NFF/FIFA in
particular. The assessment explains why the UNGC may be more suitable for
FIFA/NFF than UN Guiding Principles and the Organisation for Economic Co-
operation and Development (OECD) Framework (the full assessment can be
shared by NFF with interested parties).
FIFA is aware of the UN Global Compact and is interested in becoming a
member, but does not consider this a priority at the moment as they are
currently following the above frameworks. They also do not consider it an
either/or situation, and will consider membership in UNGC based on its own
merits when the time is right. FIFA has a direct link to the UN system.
Initiatives1 NFF shall secure a binding assurance from FIFA that the award
criteria adopted in 2016 will apply to all future FIFA
championships.
NFF shall obtain a commitment from FIFA confirming that in all future
championships they will draw up detailed strategies for the actual
execution of the championship. While the award criteria and
policy have been made permanent in FIFA, the framework for the
actual execution applies only to the World Cup in Qatar.
NFF shall ensure that FIFA’s rules relating to human rights
requirements when awarding championships are complied with in
connection with all votes at the FIFA Congress, and that no
championship is awarded outside this regime.
NFF shall demand that all championships are predicated on members
of the free press being granted entry to the country and access to
the facilities before, during and after the competition. This must
also include Club World Cups that have already been awarded.
1 Some of the initiatives are lumped together, as here, because they are understood and treated together by NFF.
20Progress reports The changes asked for in the initiatives regarding the awarding of
championships are already being implemented in FIFA. NFF has in meetings
with FIFA discussed and gained insight into the methodology and variations for
the different championships. NFF considers that the work in this area is
satisfactory, but will follow up and monitor the processes and outcomes of
future championship awards. Considering that the purpose of the initiatives is
to ensure important rights in connection with the awarding of future
championships, the attention to this should be secured in the NFF long-term
human rights strategy.
Current situation FIFA informs that since 2017 the bidding criteria have been used for all
championships, excluding the Club World Cup. For the large championships
FIFA asks for a lot (Guide to Bidding Process). For the smaller tournaments
(U17, U21) the risk level is not considered to be as high, so the requirements
match the risks. For these, FIFA is doing the context evaluation, and asks the
host country to fill in templates about key risks areas, workers' rights, and anti-
discrimination. For large championships, everyone can bid, and the congress
will decide, including a pre-screening by the council. FIFA also does the risk
assessment before it goes to council, so human rights will be evaluated twice
before any bid goes to congress.
The host country is asked to sign a Human rights commitment. This document
also includes the freedom of press. If the host country does not wish to sign the
commitment, this is not an automatic disqualifier, but considered for the risk
and context evaluation. There is a big opportunity for football to impact the
world concerning human rights, and by excluding a lot of countries you will not
reach them, instead FIFA looks to bring changes to them. For the context
assessment, FIFA looks to the UN, Amnesty, and Freedom House.
For the requirement of free press access, such guarantees exist for all
tournaments and are included in the hosting agreement. FIFA points out that
this has not been a major issue at previous tournaments (with some exceptions
that were dealt with), but that they nonetheless are looking at whether there
can be stronger language on press freedom included in the guarantees and
requirements. Even though the World Cup bid process for Qatar or Russia did
not include human rights, it did not stop FIFA from including it in further work.
One exemption from the bidding criteria is the club championships. The award
to China was an appointment, so there was no bidding process. Human rights
were a part of the conversation in the awarding process, but the criteria for
human rights will be strengthened in the future.
Regarding detailed strategies for each championship, FIFA now has a process
for this, which includes stakeholders and local organizations. This approach is
now being used in Australia, and will be used for every larger championship.
21Initiatives NFF shall work to ensure that future awards are withdrawn if the host
country has not met FIFA’s specific change requirements within a
specific timeframe.
Progress report NFF has through meetings with FIFA and discussions with human rights
lawyer, Pia Goyer, come to the understanding that working towards achieving
what NFF perceives as a set rule for withdrawal, is not aligned with the
dialogue line and the UN Guiding Principles. NFF may need to adjust the aim
for this initiative.
Current situation FIFA always has a clause in contracts which allows for withdrawing the award
from a host country in case they do not meet criteria, but it is not clearly defined
at what point this would happen. Such a decision would be political, not
something decided by the administration through their work. FIFA explains that
they consider using the threat of taking the World Cup away as a useless tool
in the day-to-day dialog for changes, and believes it should only be a last resort
in severe situations. According to the UN Guiding Principles, walking away
should be the very last option. Work is now being put into making the awarding
criteria and process as good as possible, to avoid the need for such an action.
INITIATIVES AIMED AT UEFA’S STRATEGY, STRUCTURE, POLICIES, RULES AND REGULATIONS
Initiative Take the initiative to ensure that UEFA’s award criteria and procedures
have the same minimum requirements as FIFA.
Progress report This work has not yet started, but the foundation for the discussion has been
laid with the creation of the new UEFA working group. NFF has secured a seat
in this group and plans to start work related to this initiative shortly.
Current situation UEFA added requirements in 2017 containing specific criteria relating to the
respect of human rights. The requirements are based on the UN Guiding
Principles on Business and Human Rights and other UN conventions, and were
developed in close cooperation with Sports and Rights Alliance.
22INITIATIVES DIRECTLY AIMED AT NFF’S STRATEGY, STRUCTURE, POLICIES, RULES AND
REGULATIONS
NFF shall make more explicit in its strategy that respect for human rights
Initiatives is a key aspect of Norwegian football’s international values and interests.
Work on human rights in general must be reported to the Annual General
Assembly, as well as status on concrete initiatives.
NFF shall review the Ethics Committee’s mandate and function, and give
it responsibility for verifying that the human rights-related measures
adopted by NFF’s Annual Congress are actually implemented. This
means reporting to the Annual Congress on the implementation of
decisions, starting with the Annual Congress in 2022. To ensure the
Ethics Committee has the capacity and competence needed to perform
this additional task, the Commission urges the forthcoming Extraordinary
Congress to consider a resolution to increase the Ethics Committee’s
membership.
NFF shall make sure to act as a “responsible consumer” in connection
with Norwegian participation in international events, by choosing
suppliers who can demonstrate that they are working actively to avoid
involvement in gross human rights and/or labor rights abuses.
NFF should develop a comprehensive strategy for how Norwegian
football can strengthen its own participation in and ability to influence
international forums and committees, in order to increase acceptance of
Norwegian football’s priorities, particularly work to promote human
rights, participation and equality, and to combat sports-washing and
corruption. NFF should establish a committee to propose guidelines for
Norwegian football on matters relating to human rights.
NFF should draw up a strategy for how Norwegian football can
strengthen its participation and influence in international forums and
committees, in order to gain acceptance for Norwegian football’s adopted
priorities, particularly efforts to promote human rights, participation and
equality, and to combat sports-washing and corruption.
NFF should review Norwegian football’s procedures for deciding which
candidate to host championship competitions NFF should support.
23Progress report A suggested mandate and appointment of a committee on NFF’s international
strategy has been approved by the board. The committee is assembled, and
the first meeting took place on September 29th. There will be an overlap from
the current working group in the administration to the strategy working group, to
ensure transfer of knowledge. The next stage is to lay out a timeline for this
work, with the final deadline aimed for December 2021.
The direction and strategy of this initiative has been adjusted accordingly, and
NFF has taken a very active role in moving along the human rights work both
through discussions with FIFA and other stakeholders, and through securing a
seat in the UEFA working group. The voices from the general assembly have
been heard, and NFF is looking to be much more proactive in this area in the
future.
Current situation NFF is already committed to promoting human rights and equality in the rest of
the world both through strategy and implementation of Football and Social
responsibility projects in 15 countries (Middle East, North Africa, Southeast
Asia, Balkans). Today NFF has one of the largest social responsibility
departments in any football association (21 employees including local
representatives in project countries). The scope of both the strategy and the
mandate for the department will most likely be broadened through this revision.
NFF is engaged directly with both FIFA and UEFA to strengthen the focus on
human rights.
NFF has established contact with the Foreign Department in Norway to align
policy with them.
24Initiative NFF should introduce procedures to offer players and support staff
linked to national and club teams a thorough introduction to the human
rights situations prevailing in the countries they are going to visit, to
build trust and pave the way for informed, individual choices concerning,
for example, the exercise of free speech.
Progress evaluation This is ongoing work, and will need to be adjusted for each new destination, but
a basic framework with plans for the upcoming championships has been
presented by a working group from the administration tasked with this.
Current situation NFF has established contact with the Foreign Department in Norway to align
with them. The next stage will involve elaborating this framework and
establishing what routines are the most suitable and practical.
INITIATIVES FOR COOPERATION WITH OTHER NATIONAL SPORTS BODIES
Initiative Invite the Norwegian Olympic and Paralympic Committee and
Confederation of Sports to engage in an inclusive process to agree on
how we can jointly build and rebuild trust in sport’s international ethical
foundations through tangible steps and measures to prevent sports-
washing and help to strengthen human rights.
Progress report NFF has had an important role on this initiative. NFF’s Vice President, Ane
Guro Skaare-Rekdal, represented NFF in the committee and Anders
Hasselgård assisted the secretariat. The Norwegian Olympic and Paralympic
Committee and Confederation of Sports (NIF) started this work on August 17th,
and finalized with a policy document titled ‘Norwegian sport’s values and
international ambitions’. The final draft was ready in time for NIF’s extraordinary
assembly in October.
Current situation NFF has taken a leading role in the collaboration between various Norwegian
sports institutions in order to put pressure on this subject. Representatives from
both the NFF board and administration have been named to a working group
starting this project.
25Action points
NFF is working continuously towards the purpose of each respective initiative, as detailed above. In
addition, below is a list of concrete options for action points considered to solve particular issues or
bypass identified hurdles. The situation is constantly changing, and NFF will need to evaluate what is
believed to be the best method to achieve a goal at any given time.
In the continued work through the UEFA human rights group:
• Obtain a full overview of the specific details about what differs between the FIFA and the UEFA
bidding requirements. In this analysis it will be relevant to look at the last UEFA bidding process
(Turkey and Germany for Euro 2024), to see how the new requirements regarding Human Rights
were applied.
• Consider/suggest a joint (online) model for educating and informing players, coaches and
supporting staff on human rights topics, as well as rights and duties in accordance with rules and
regulations. This can ensure basic knowledge and shared understandings throughout the UEFA
countries.
• Propose that UEFA encourage other international sports organizations to start the same process
of including/reviewing human rights in their strategy and bidding requirements.
• Ask FIFA for a written statement from the authorities in Qatar guaranteeing the safety of the
LGBTQI+ group during the World Cup tournament, ensuring that they will not be legally
persecuted for any behavior associated with LGBTQI+, such as same sex couples holding hands
or kissing publicly. It is important that the guarantee will come from Qatar, not FIFA. This demand
will be much more forceful if UEFA is the one behind it, instead of NFF alone.
• Suggest UEFA become a member of UN Global Compact.
• Coordinate a European effort towards the proposed migrant center. To ensure the establishment
of such a center, the UEFA group should consider writing a letter expressing clearly to FIFA that
this center is something that should also be a main goal for the political influence on Qatar. A
letter can be written to the FIFA president asking for this.
• Discuss UEFAs options for reacting to incidents. FIFA can potentially help to quickly solve single
incidents, and the more federations reacting to serious incidents, the more pressure FIFA can
apply in the situation.
• Prepare suggestions for procedures for FAs to conduct due diligence with regards to human
rights for use in connection with travelling, purchasing etc.
In the continued dialogue with FIFA:
• Discuss what a mechanism for withdrawing an award in case of non-compliance could look like,
and what ‘change requirements’ should trigger such a withdrawing of rights.
• Engage in, and when relevant also support, the work FIFA is already doing through asking
questions and offering assistance to keep focus on important issues.
• Keep asking for updates on the situation regarding the migrant center, the reporting website, and
the status of inspections and reforms in the hospitality and service sector.
• Once launched, give feedback on the reporting website. More particularly, look at KPIs and
information about how improvement is measured. For example, ask for numbers on how many
workers at World Cup sites are waiting for their money, and how has the development been in
this area?
• Encourage FIFA to exert influence on a higher political level to seek that the government of Qatar
can agree on how to internally divide responsibilities between departments, and to ensure that
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