International comparisons of national sport integrity systems

Question 1

Executive Summary

Accepted Answer

1. In recent years a number of integrity systems and bodies have been established in sport, at both a national governing body and international sport federation level.

2. More recently there has been considerable developments in the national coordination of sport integrity bodies.

3. DCMS identified that new research was needed to:
(i) draw together information about the different types of national integrity organisations being created;
(ii) identify how they had been established; and
(iii) gather evidence on how they were working in practice.

4. The specific aim of the report was driven by 1 main research question, and 1 sub-question:

What dedicated sport integrity organisations are in place internationally, and are there opportunities for learning to inform the UK system?
Where a new model has been established, has this been done through legislative changes?

5. The present report outlines the nature and functioning of 10 National Integrity Bodies (NIBs):

7 which are already functioning (Australia, Austria, Canada, Denmark, Estonia, Finland, and Switzerland)
1 which is partly functioning (Malta)
2 which are in the process of establishment (Luxembourg and New Zealand), the latter being very close to operational activity.

6. The report utilises a multi-method approach, incorporating desk study, a short questionnaire, and anonymised semi-structured interviews with leading personnel of the NIBs.

7. From the desk study it was clear that there were very significant differences in the size and resourcing of the NIBs. The largest (Australia) has an annual budget of £30 million and 158 full-time employees (FTE), while Estonia has 8 FTE and did not report its annual budget. In the middle are Canada (budget £6 million, 45 FTE and 70 part-time employees (PTE)) and Denmark (budget £3.5 million, 18 FTE).

8. All NIBs have a “broad integrity” approach.
a. Anti-Doping is the only integrity area that is catered for across the sample.
b. All NIBs reported activity in Safe Sport, but in Canada the national integrity body (NIB) plays a diminished role at present in comparison to a stand-alone Safe Sport entity.
c. All but one in the sample engage in sport competition manipulation activities (betting and non-betting related) but in 2 cases these are only reported as partial activity, alongside other entities. Only Canada, Japan and New Zealand are not signatories to the Convention on the Manipulation of Sports Competitions (‘the Macolin Convention’).
d. Only half of the sample were engaged in anti-corruption activities.

9. The interviews were recorded and transcribed. 5 major themes emerged:
A. landscape/context for NIB development
B. establishment of the NIB
C. setup and governance of the NIB
D. operational elements of the NIB
E. outcomes of the NIB to date.

10. Key findings from the data are that:
a. All of the NIBs were in some sense created on the back of (nationally differing) crises or scandals, the particularity of which drove issues such as foci, structure, and funding.
b. Political will followed, to a certain extent, public perceptions of the seriousness of the various crises / scandals.
c. The establishment of a specific mandate, with clear definitions, regulations, and powers was universally endorsed as absolutely critical.
d. A legislative base was only witnessed in one NIB, but all said that this was a key to the (more) efficient functioning of the NIB.
e. A national integrity code or national integrity framework was vital for coherent, consistent and transparent functioning.
f. The development of such a code / framework should be viewed as the final outcome of extensive consultation with all key stakeholder groups (administrators, athletes, coaches).
g. The NIB, by incorporating a “broad integrity” approach, had to face the challenge of developing systems, personnel and culture that reflected very different needs (comparing anti-doping, safe sport, sport competition manipulation) in response to integrity offences that were sometimes civil (merely sport-related) or criminal.
h. The ability to share information reciprocally with external agencies (e.g. law enforcement agencies) was universally supported though only extant in Australia, supported by legislation.
i. Some NIBs received disclosures and only conducted investigations but had no authority or mandate to establish hearings and rule therein.
j. Several NIBs were sceptical of the role of national governing bodies (NGBs) to regulate themselves.
k. All NIBs spoke of the necessity of collaboration at three levels: athlete stakeholders; sport stakeholders (including National Olympic Committees, and National Sport Confederations); and relevant sport and non-sport ministries.
l. All NIBs reported the challenge of developing relations with the sport ministry (or relevant configuration of portfolios, including education, health, justice) but reported that cross-ministry collaboration was essential.
m. Given that all the sample incorporated the national anti-doping organisation, they were all supportive of building from that structure to create synergies, efficiency gains and economic cost controls.

Question 2

Introduction and context

Accepted Answer

In 2019, UK Anti-Doping (UKAD) commissioned a report whose aim was to map the landscape and to make recommendations as to the future, integrated, development of sport integrity in alignment with the good governance of sport within the UK. The report “Integrity in Sport: Mapping the UK Landscape” (McNamee, Parry, and Phelps 2020) highlighted the heterogeneity of the landscape in terms of:

(i) definitions and conceptualisations of sport integrity;
(ii) drivers and threats to sport integrity;
(iii) current approaches to sport integrity;
(iv) organisational structures and partnerships for sport integrity; and
(v) models of delivery and compliance of sport integrity.

In addition, it made 24 recommendations, 4 of which were key:

The formation of a UK-wide Sport Integrity Forum to develop and share good practice and to lead development of a national sport integrity plan.
The establishment of a UK-wide agreement on the operational definition of sport integrity.
The development of a UK-wide sport integrity education strategy.
The development of practice-sharing criteria and partnerships according to the resource levels and shared integrity threats.

The intervening years saw several national challenges to national policy development in sport and elsewhere, including the UK withdrawal from the European Union, and the COVID-19 pandemic.

Elsewhere in the world, the development of national integrity bodies has developed apace. The first integrity body, the Canadian Centre for Ethics in Sport (CCES) was formally established in 1995 with a merger between the Canadian Centre for Drug-Free Sport and Fair Play Canada in 1995. The Canadian Centre for Drug-Free Sport (Canadian Anti-Doping Organization, later renamed) was founded in 1991 on the back of the Ben Johnson doping scandal at the 1988 Olympics.

Other nations have (initially) followed the World Anti-Doping Agency (WADA)-driven model of national anti-doping organisations (NADOs), without a broader brief.

A series of national and international scandals brought about various crises around the globe resulting in political pressures to develop integrity bodies. These have been independent bodies within individual sports or multi-sport, nationally operating, entities. A similar movement was seen within sports: some international federations (IFs) created integrity bodies that were either functionally independent though financially dependent on the IF, while others created entities within the organisation itself and with functions that were reported according to the internal governance therein.

Examples of the former include Athletics Integrity Unit, Biathlon Integrity Unit, Gymnastics Ethics Foundations, International Tennis Integrity Agency (formerly TIU), Aquatics Integrity Unit.

Examples of the latter include the ICC, FIFA, International Table Tennis Federation and Union of European Football Associations.

The developments around the development of NIBs is undoubtedly gathering pace. Most recently, a group consisting of representatives of NIBs and NADOs who already are established as an NIB, are in the process of doing so or have a potential interest in expanding into this sphere, was held immediately prior to the annual WADA Symposium in Lausanne (12-13 March 2024), organised by the Finnish Centre for Integrity in Sports (FINCIS).

The chief outcome of that meeting was an agreement by 10 NADOs to establish a global integrity offices network. Seven of those organizations are already working on wider sports integrity tasks and the rest of them have plans to do so. The network is open to all offices that are working on sports integrity willing to abide by the rules and responsibilities of the network. Its initial goals are focused around information sharing, learning together, and the development of further integrity organisations. Sport Integrity Australia will be the initial Coordinator and Secretariat of the network, while FINCIS is co-coordinator.

Aware that a number of countries around the world had created dedicated integrity bodies to deal with issues around sport integrity, DCMS identified that new research was needed to:

draw together information about the different types of national integrity organisations being created
identify how they had been established
gather evidence on how they were working in practice

Question 3

Aim

Accepted Answer

The aim of the report was driven by 1 main research question, and 1 sub-question:

What dedicated sport integrity organisations are in place internationally, and are there opportunities for learning to inform the UK system?

1.1 Where a new model has been established has this been done through legislative changes?

Question 4

Methods

Accepted Answer

It was agreed that the information required to address the research questions could not fully be obtained in a desk study. Therefore, a multi-method approach was adopted. Following appropriate desk study background work, the research moved to 2 forms of data collection. This entailed a written questionnaire (see Appendix 4, PDF 49KB), which was followed up by a semi-structured interview. In total 10 interviews were undertaken, one including 2 respondents. Interview durations were between 48 minutes and 88 mins (average 65 minutes).

Research ethics approval

Research ethics approval was granted from Swansea University on 13 January 2024 (approval number 1 2024 9025 7774).

Consistent with norms in social science research, a participant information sheet was constructed (see Appendix 2, PDF 117KB), and an informed consent form (see Appendix 3, PDF 30KB) was distributed to a leading officer of the NIB.

Sample

Identification of the potential participants was facilitated through the international network of the researchers and confirmed by digital search. The response rate was 100%.

In terms of sample population, DCMS had requested that the research must minimally include 7 nation states where a national integrity body had been identified.

These were:

Australia
Austria
Canada
Denmark
Finland
New Zealand
Switzerland.

It should be noted that in the case of New Zealand, the entity will not formally commence its work until 1 June 2024.

National integrity bodies (NIBs) from both Estonia and Malta were also added. Given the New Zealand inclusion, it was thought prudent to include other bodies that were in the process of becoming. In addition, therefore, Luxembourg (which is expected to establish its own national integrity body in 2025) was also included.

With respect to the sample, and in compliance with the research ethics approval, we confirm that the sample of interviewees was comprised of leading officer(s) of the integrity body or those charged with bringing the integrity body into operation. Further details of roles and job titles cannot be supplied, as this would compromise the anonymous conditions of the approval. Participant numbers used in this report (for example, where including a quote from ‘Participant 1’) have been randomly assigned.

Austria was omitted from the study because it does not have an NIB as such. Rather “it has become standard practice in the Bundesministerium Inneres (BMI, Ministry of Internal Affairs) to establish Task Forces (PDF, 510KB) with the involvement of the relevant stakeholders to ensure the safety of the Austrian delegation (athletes, trainers, sponsors, media, other accredited persons) and the Austrian visitors as best as possible, as well as to support efforts of the host countries to ensure adequate policing and security” around major sporting events. Rather than a permanent entity it is more of an ad hoc collaboration focussing specifically on the direct integrity threats that come with the organisation of major sporting events.

Further research revealed that Austria, though it has a Security and Sport Platform, was too limited in terms of its scope and its law enforcement origin. It shared offices with 2 other non-governmental organisations (Play Fair Code, NADA) and a Sexual Harassment Unit, under an umbrella name “Respect and Integrity in Sport”, and was thus discounted.

In addition to the DCMS list, Estonia, Japan, Luxembourg, and Malta were added to the research sample. These examples are slightly further advanced than other countries where there is nascent, if publicly expressed, interest in the development of an NIB. In the Netherlands, a process has been put in place to explore the possibilities for a Netherlands NIB following several safe sport scandals in different sports.

In France, a report “Remise du rapport du Comité national pour renforcer l’éthique et la vie démocratique dans le sport” (“For a more democratic, more ethical and more protective sport”) was published in December 2023. The principal recommendation of this report is to create an independent authority charged with the protection of ethics in sport.

In Lithuania, the process of adding the task of combatting sport competition manipulation to the Lithuanian NADO has been set in motion.

In each of these instances the (potential) development of an NIB is too premature to have significance for the current research. Clearly, however, it will be useful to track their development toward a fully functional NIB on a prospective basis.

In the first instance a short questionnaire was devised in order to extract key basic information around the central themes and issues that formed the study. A short questionnaire was emailed to give respondents a chance to understand our brief and to report basic factual information that forms part of our country factsheets (see Appendix 1). This served as the basis of the semi-structured interviews that followed.

All questionnaires were written and responded to in English, and all interviews were conducted in English.

Figure 1: global sample

Countries with NIB	Countries in development
Australia	France
Canada	Lithuania
Denmark	Malta
Estonia	Netherlands
Finland
Japan
Luxembourg
New Zealand
Switzerland

Countries are listed in alphabetical order. Where participant numbers used in this report (for example, where including a quote from ‘Participant 1’), these have been randomly assigned.

Methodology

Both researchers were present in all interviews, adopting different but overlapping roles. The lead author took a leading role in each interview, while the second author took the role of annotating and matching the conversation to the interview guide which was not slavishly followed. Rather, in an attempt to foster a naturalistic feel, respondents were encouraged to shape their answers in a less formulaic way, and the second interviewer regularly asked for comparisons across the themes and probed consistencies between the questionnaire and the verbal responses.

For the purposes of probing nuanced ethical, legal and political dimensions the interviewees adopted a conversational style of interviewing. All interviewees were reminded of the central parameters of research ethics approval including matters of anonymisation and confidentiality. These gave participants assurance to speak freely and they were invited to stipulate – if required – where comments were strictly off the record. Given the status of the respondents and their public role all were appropriately careful in their responses but did reveal nuances especially when it came to the identification of obstacles or barriers to NIB developments, as well as the identification of levers for change, which were often enmeshed in legal and political issues.

The content of each interview, though shaped by the interview guide, was not identical in every case for 2 reasons. First, the respondents were free to take the conversation where they wished. Second, a certain amount of learning took place as the interviews proceeded. Thus, based on the emerging insights of the interviews, the researchers were able to identify matters beyond the original guide and probed those. This feature also affected the analysis of the interview data.

All interviews were conducted over Microsoft Teams, even where face-to-face interviews were held, and all were simultaneously transcribed in the software of that package. These were later sense-checked, since the automatic transcription service is not ideally suited to variations in phonetics (such as are characteristic of international research interviews). We have adopted a naturalistic tone where possible – allowing the authors’ words to come through. Sometimes this has had to be adapted to add missing words (presented in [square brackets]) or by showing where the grammatical mistake is in the original (using the standard technique ‘(sic)’).

All interviews were inputted into qualitative software package Nvivo 14. The process of identifying themes and subthemes proceeded according to the following protocol.

First, the first interview that was conducted was read by both viewers independently. They assigned themes and sub-themes (i.e. codes) to each topic. The lead author proceeded in an inductive manner (i.e. he constructed themes without reference to the interview guide, noting them in temporal order). The second author used the interview guide as a reference to the themes (i.e. codes) and proceeded to analyse the data deductively.

After this both authors compared and contrasted the themes and sub-themes and constructed conceptually nuanced labels for themes and sub-themes.

Subsequently both researchers analysed a second interview that had been conducted towards the end of the research process. Again, they compared and contrasted the themes and sub-themes that they had developed from the first interview, adding new themes or sub-themes, and altered the specific names of many themes and sub-themes giving them greater nuance and applicability to all the remaining interviews that had been conducted to ensure comprehensiveness of the data analysed. This gave assurance as to both the validity and reliability of the analysis of the interviews.

During the analysis of the remaining interviews the researchers were open to the possibility of themes or sub-themes emerging that had not already been identified. These were very limited in number, though a slight nuancing of the labels of the sub-themes (i.e. codes) did occur. Some doubling-back on earlier interviews was conducted to incorporate the learning, though this was limited (in order to avoid a vicious infinite regress).

In several cases respondents referred to policies, commissions, and other public domain information. In each case these were requested and incorporated into the narrative of this report as hyperlinks where possible, and they also form part of the country factsheets (see Appendix 1).

Question 5

Data themes presentation

Accepted Answer

The data from the questionnaires and interviews were grouped into 5 themes:

A. Landscape/context for NIB development; B. Establishment of the NIB; C. Setup and governance of the NIB; D. Operational elements of the NIB; and E. Outcomes of the NIB to date.

Each theme was further broken down into sub-themes, and sub-themes within those. In this report discussions are focused on the first 2 layers. These are recorded in the list below.

Data themes presentation

A: Landscape / context

Roles of the different stakeholders
Interest stakeholders in integrity
Barriers (distrust, culture, bad practices, incentives)
Catalyst
Scandal
Legal / sport structure
6(a). Broader sport (integrity) framework

B: Establishment

Problems / successes in unifying
Stakeholder driving / opposing forces
Integrity champions
Denial

C: Setup / governance

Foundation build of / in (NADO, ministry etc)
Legal structure
2(a). Single point of contact (SPOC)
Scope
- different threats, sport competition manipulation (SCM) (Macolin, GOC), anti-doping
- in all cases NADOs, SG, corruption, governance, see survey, compliance
Appointment process
Composition
Influencers
Sport autonomy
Authority / mandate given (legal basis)
Conflicts of interest
Independence

D: Operational

Funding
Human resources
2(a). Full-time equivalent (FTE)
2(b). Tasks
2(c). Competences
Cooperation and collaboration internally
Cooperation and collaboration external stakeholders
4(a). Across specific integrity fields
4(b). Law enforcement agency (LEA)
4(c). Consultation (in all phases)
4(d). International
Data sharing
Definitions / code / rules
Procedures
7(a). Education / prevention / awareness raising / capacity
7(b). Reporting
–7(b)(i). Whistleblowing / disclosure reporting
7(c). Triage
7(d). Investigation
–7(d)(i). Powers
7(e). Judgement (tribunal / hearing / sanction / dispute resolution / arbitration)
7(f). Counselling
7(g). Support (in all phases, from education and investigations to sanctioning)
Opportunities / obstacles
Levers / powers
Non-recent cases

E: Outcomes

Reports
Investigations
Cases
Sanctions
Learnings
Wins / key success factors
Threats
Future

Data themes discussion

Question 6

A. Landscape/context for NIB development

Accepted Answer

It will surprise no reader to appreciate the fact that in the vast majority of cases a crisis or some kind of integrity related scandal was the catalyst for the development of an NIB. What was noteworthy, though, was the source of the scandal. While there was a growing awareness of sport competition manipulation (SCM), in particular sport betting-related integrity issues, the sport of gymnastics was most frequently cited. It was suggested by more than one participant that this presented an opportunity given the high media interest in the protection of minors in sports. This is particularly noteworthy in the context of the UK, following so soon on the publication of the Whyte Review into gymnast wellbeing and welfare.

Flowing from the crisis / scandal genesis a series of challenges arose, concerning the autonomy of sport, inherent conflicts of interest, the very strong emphasis on the need for consultation and clear mandates. These are highlighted below with illustrative quotations.

Crisis / scandal genesis

It is important to be specific about the crisis(es) or scandal(s) that prefigured the development of NIBs. On the one hand, there is global awareness of poor governance in a number of sports, but these were not noted as specific drivers for nationally based developments. Thus, in the most obvious and well cited of cases, the soul-searching that went on in Canadian sport after Ben Johnson’s infamous anti-doping rule violation. While that was the driver to merge existing entities (Canadian Centre for Drug-Free Sport and Fair Play Canada) and develop the first pan-sport integrity entity, it should be noted that this did not incorporate issues that were not pressing in Canada. Notably, for example, safe sport was a much less high-profile issue then. So, while the Canadian vision was to extend beyond anti-doping, it is not wholly inclusive of the scope of “broad sport” integrity, even though it is well beyond the frame of “narrow” sport integrity (McNamee, 2015) which evolved more recently in relation to match fixing specifically and sport betting related integrity more generally.

One participant put it succinctly:

“So unless there’s a big crisis, I doubt that there will be big changes in [nation]”

– Participant 10

Equally, one can find high-profile cases of systemic integrity failings in relation to Australian anti-doping in the Essendon case, but in many cases it was gymnastics abuses that were highlighted because of their media-attraction and the reputational damage that attended them.

But many saw gymnastics as a catalyst.

“And then followed a series of other dramas replicated really around the world. And almost inevitably, sadly, a review into gymnastics. Sports put huge pressure on athletes to succeed, and at almost at all costs. But, because of the funding model … but also, athletes are reluctant to complain about their treatment because of the potential impact on funding.”

– Participant 8

Additionally, another remarked:

“Gymnastics was the tip of the iceberg.”

– Participant 6

Then continuing in reference to attract other sports’ buy-in they observed:

“This is abuse of children in sports, sports, our national heritage in [nation], [do] we really want to go down the path?”

– Participant 6

Later they added more in the following exchange:

Participant 6:

“Are they [national governing bodies] going to be ready for the onslaught? They can either come and do it through us and if they wanted us to coordinate that form … Is a set of policies that we’re going to make consistent across sport. We started the conversation with abusive children in all the cases of abuse that we’d seen in [nation].”

Interviewer:

“Did you see … who wants not to open the door on abuse of minors? Right. Did you see that strategically as a kind of an easy win? You could get all that sign up to that if you can … if you get them with children, everything else falls below them. But you’re going to allow the abuse of children to happen in your sport?”

Participant 6:

“On the back of gymnastics, what we were doing, all that we had … two or three other sports to come forward. So we’re gonna do reviews for them as well on … on behaviours, then investigations. And it was all done under the powers of the sports policy. If it was criminality through our relationship with law enforcement, it went out the door to police. Once it hit that criminal threshold through our agreements with them and having them embedded with us. So we’ve got law enforcement, border intelligence agencies, impediments.”

The rise of athlete-recognition

It is only in recent years that the movements variously described as athlete-centred (for example, athletes’ rights, athletes’ voices, athlete representation) have begun to take centre-stage in sport integrity discussions. It is probably that it is driven by the success of safe sport innovations, in addition to the older forms of athlete representations (such as trade unions and athlete commissions), but this is part of the landscape of the emergence of NIBs.

Athletes have long denounced what are, in their perceptions, complicated compliance regimes. Notably the whereabouts declarations of athletes for anti-doping surveillance generates considerable resistance and negative dialogue, but the NIB development is positioned by some as an athlete-centred response.

The following participant acknowledged this and the importance of getting the athlete stakeholder group (if it can be talked of in the singular) at the heart of the process:

“We are spending a lot of time talking to key influences throughout the country, particularly our player association groups. Elite athletes, the real influences in sport to make sure they are on board with what we’re doing. So I my (sic) biggest learning is you can’t consult enough about something like this.”

– Participant 8

One participant put themselves in the shoes of the athlete who wishes to register an integrity breach, linking the idea of a ‘one-stop shop’, with the location of that NIB “shop”:

“OK, should we place it in a separate function but inside the Ministry of Culture maybe and people were like ‘no athlete would ever walk into a ministry to report something or like so where, where would the trust be and so on’, so that so it ended up that that they didn’t even to their board present different scenarios.”

– Participant 10

They continued:

“I think, for example, the [nation] NOC, [nation] National Sports Federation, I don’t think they necessarily work towards integrity, because as an athlete you shouldn’t have to, OK, what do I go to answer doing … then work with what … do I go to my International Federation’s whistleblower function or whatever? What do I go to the NOC with? What do I go to the gambling authority with or whatever? So it’s so confusing landscape and that’s an important focus or point I would say as well dealing with this.”

– Participant 10

The above quotation links into another theme: sport autonomy leaches into conflicts in sport integrity management.

Conflicts of interest are a catalyst for change

The ‘status quo ante’ (previous state of affairs) was that sports, because of the autonomy they enjoy, at least in the European model of sport, are left to self-regulate. The growing recognition that oversight of integrity procedures, from regulation development to compliance and sanctioning oversight, drove the development of many of the NIBs in the sample. When questioned on this, one participant observed:

“I am fully agree (sic) in this because if you look at … very small, everybody knows everybody. It’s very difficult, very difficult to. To stand and say this is this is not OK. This is problem and that’s why… that’s why we need the approach outside of federation, and but I’m agree (sic) that not all the federations will cooperate in this.”

– Participant 1

Another remarked more pointedly:

“The culture of sport and understanding why the culture of sport is so toxic currently, what’s leading to that, and how do we change that? And changing that is about instilling the proper values that we want in the support system from the starting point and being able to ensure that we value those values that we fund based on those values, that we move the whole system forward in that way. So that’s the moment in time where we find ourselves right now.

“I can’t necessarily predict what those outcomes will be, but it’s…it’s a really big, you know, opportunity to rethink the sports system in [nation] in ways to make sure that it is providing. You know the it’s the public asset and that we all want it to be and it’s not about chasing medals, it’s about ensuring that we build character and youth. We reduce crime, we increase health, we do all the things for why we fund support.”

– Participant 2

And specifically relating to SCM, where integrity breaches are likely also to be criminal acts one respondent remarked:

“in terms of competition manipulation. Bearing in mind though that adoption is still voluntary (…) proving that there was a proven track record, that sport federations, they cannot take care of that issue themselves because they’ve done it so.”

– Participant 8

These remarks identify the normative causes behind the development of NIBs in the sample. We move now to consider what forms those developments have taken.

Question 7

B. Establishment of the NIB

Accepted Answer

In several interviews, the phrase “never waste a good crisis” was uttered. Different NIBs were driven by typically nation-specific crises, but the response to these is different. This is a complex theme. Responses to questions around the establishment of the NIB range from sport-specific issues to meso-level governance and structural considerations that differ from country to country.

At a macro level, the mixture of legal and political aspects are deeply intertwined. These latter considerations are both more generalised and less easily translatable as a whole. Consideration must be made in particular to the applicability of 3 NIBs existing within the Commonwealth intergovernmental space, where some geopolitical and legal resonances clearly already exist.

Finally, an issue that applied in all cases was the fact of the pre-existing National Anti-Doping Organisation (NADO), and the extent to which the NIB developments were associated with that structure. Whichever route was adopted, there seemed to be widespread acknowledgement of the benefit of incrementally building the mandate / scope starting from existing consensus and structure(s).

Authority / mandate

The need for a very clear authority or mandate at governmental level was clear from all interviews. This is almost certainly the first and most important point that arose across the range of interviews.

In the sample, the mandated powers and scope varied widely. Those with limited powers critically recounted their inability to perform to a level they aspired to. The mandates ranged from empowerment to educate, investigate, to sanction, to share data (reciprocally) with law enforcement agencies. The latter power was only found in 1 jurisdiction, but was regarded as essential therein.

In essence, 2 components were established in the dialogue:

how to get sports “on board”
how to secure political will and leverage

With respect to sports, 1 participant observed a phenomenon that was widespread across the NIBs:

“That the biggest challenge, the thing that keeps me awake at night, is simply how we can get the spread across the country into every club you know, so that whole adoption model is very, very challenging because as I’m sure it’s the case in the UK and …., you know the structure in football may be dramatically different to the structure in canoeing.”

– Participant 8

Within that, dialogue with sports is crucial.

“The challenge that we have had and probably continue to have is as much as we have a broader mandate than anti-doping. It’s not crystallised there; it’s not made concrete in a meaningful way. Whereas our anti-doping mandate is through the UNESCO Convention and the Government of [nation] ratification of that convention.”

– Participant 2

There also exists a challenge in relation to the perceptions of stakeholders, which is more or less related to the mandate or authority that the NIB has been afforded. This moved between their powers to educate, regulate, and sanction:

“So, so we were asking and I personally was asking can we do that, can you be the police and the guiding hand at the same time. To be honest, I don’t have the…I don’t have the answer but the number of reports that we do get leads us to the assumption that in the eyes of the athletes, we are very well capable of doing that, and at the same time I have to add that I’ve never perceived our role in anti-doping as police. I’ve never, we have never, interpreted it that way, but at the same time you know you can’t change like the public.”

– Participant 5

Another moved from a perception of the need to formulate new and different set of rules (e.g. for safe sport) from anti-doping, to a perception of a quasi-law enforcement agency:

“We were thinking why we maybe shouldn’t do it. There’s only one … really …that’s the different rules. That that’s the perception of the of the rules. I personally think it’s not actually a different role but the perception’s different and the perception in anti-doping unfortunately still is: police.”

– Participant 5

In broad support another respondent spoke of the need for strong alignment with sport stakeholders:

“make sure you listen to sports if you if you’re really gonna go out in the partnership model, which will get them to “buy in”, rather than in in a regulatory model. Really wanna get into buy in, actually listen to them and show them how you’re embracing some of their… they run the sport so they know it better than most. So probably… listen we had a couple of areas where I would say we decided that ‘we know better’.”

– Participant 6

Somewhat pointedly, they continued that persons who had not adopted the idea of securing the ethos of securing sport to buy-in had no future in the NIB:

“There’s a couple of people - they’re not with us anymore.”

– Participant 6

A simple summary of the collaborative approach is then captured by the respondent:

“We went to the sports and engaged them personally.”

– Participant 6

This point appears almost banal but it masks a challenge: which sports?; which sport structures?.

Across the sample there are very different national sport systems. A key difference was the role and power of the National Olympic Committee (NOC), and the National Sport Confederation (NSC) (with each nation having its own name and configuration). In some cases there is very little difference between these 2 entities in terms of actual functioning.

In some cases, the role of the national Olympic committee (NOC) was clearly a very powerful mechanism – not least because of their being the gatekeeper to the Olympic Games. The following quotation captures this well:

“It wasn’t too hard because we went on the back of … I went to the setup, get the buy in of sports. I went to the Olympic Committee first. There’s your first [specified number] on sports and then the Commonwealth Games, and then the Paralympics. So getting their buy-in was by going to them saying “this is abuse”. “You’re all going to wear it.” “You’re all going to have to do it.” “How are you?; your members quit.” “How did you get the mandate to go?” Go to a sport organisation and tell them that policy authority got them to give us their policy authority. We don’t have legislation for that.”

– Participant 6

The variations here were very specific in terms of leveraging sport stakeholder buy-in. Sometimes it was by the strength of personal connections of the leadership of the NIB, in other cases the NOC was critical, and sometimes it was also the influence of, for example, a powerful sport law body.

Building on NADO structures

There was almost universal support for the idea of building on NADO structures. We return to this later in relation to (for example) economic dimensions, but for present purposes the key idea was that buy-in from athlete and sport stakeholders enabled the mandate to be perceived positively. This in itself lent credibility to the functioning of, and trust in, the newly formed NIB.

The following was not an uncommon indication:

“A big benefit that we that this organisation has to deal with, other integrity issues is that athletes have confidence in the work we do in anti-doping. They may not always like it, but they have confidence that we do it and that we follow through on it, that we are trustworthy, that we’re here to protect clean athletes and that credibility as a starting point to deal with other integrity issues.”

– Participant 2

A further point was, building on that trust, to avoid potential resistance because the entity and its personnel would be starting from scratch, so to speak:

“I think is massively helpful as far as you know, a quick win is concerned. So as opposed to trying to start from scratch or create some new agency that nobody’s dealt with before and nobody knows so quick win, that would be a really, really big one.”

– Participant 2

Political will

A key point made by several interviewees related to the political appetite and support for the NIB.

Almost all interviewees spoke of frustration concerning the lack of continuity of ministers and therefore of ministerial agendas. Several cited the number of sport ministers that they had had to engage with over the process of the development of the NIB. This shifting landscape of course had direct consequences on political support, but also crucially in the financial support that they could rely upon. This is reflected most accurately below in table 3 - FTE and operating budgets.

One respondent was clear that political will could be shifted in relation to perceptions around the value of spending public money on sport:

“This is not the sport that we want to fund in the future. So money was to leverage (sic) at the end of the day.”

– Participant 5

They went on to note that public perception shifted against sports themselves and their credibility, which enabled the lever for political will to shift sport structures towards an NIB:

“Politics jumped onto the bandwagon and therefore sports had to as well.”

– Participant 5

Not every partner found the political leverage a negative challenge. One respondent spoke very positively about the excitement of being at the cutting-edge of national sport policy development.

“I really enjoyed that process because you were able to discuss the important stuff. You didn’t waste any time discussing the colour of the logo and stuff like this. It was so it was so dynamic and the collaboration with all the other organisations is so focused on the goal we need to be online, we need to go live on….”

– Participant 5

This point may be important for the selection of any leading role; experience and connectedness within the system is critical. So too is the immense passion and motivation to lead such a complex entity, nested within structures whose interests are commonly misaligned. Some respondents went as far as saying that without a well-known and well-connected “champion” their NIB would never have been created.

Finally, it is commonplace that without political will in public policy there is no financial support. Without that there can be no NIB. As one respondent put it, their strategy was in part to target the governmental treasury, not simply the Ministry of Sport, with a crucial message:

“Incremental progress starting with the Treasury host, everybody’s got to buy into like safe sport.”

– Participant 6

It seems, therefore, that at a micro- and meso-level authority will arise partly from sport structures’ legitimation of the NIB, which is critical for swift operationalisation. Notwithstanding this, at a macro-level, consistent political support is critical for the establishment of the NIB in the first place.

Where functions and powers were articulated in some kind of law, greater effectiveness was perceived to follow. Where they were less-clearly established powers, often what held the integrity system together was a series of overlapping interests, shared agendas, and very often partial, but not insignificant, financial incentives or disincentives.

Question 8

C. Setup and governance of the NIB

Accepted Answer

While it is all but impossible to meaningfully discuss the possible establishment of an NIB without a budget, one useful way to commence the general discussion was thought to be a consideration of the scope of the activities undertaken by each NIB. This at least gives a meaningful basis for political and therefore financial considerations.

Other non-financial considerations will draw upon the nature of the authority or mandate given. The most critical component here will be in relation to powers of investigation and data-sharing with law enforcement agencies.

Scope

As would have been anticipated, few NIBs undertake work in all areas, and across all integrity threats. These differences reflect cultural specificities but also more prosaic matters such as funding and available human resource.

Table 1: Scope of activities of the sample NIBs

NIB	Anti-corruption	Anti-doping	EID	Good governance	SCM (betting / non-betting)	Safeguarding	Ethics	Compliance
Australia	Yes	Yes	Yes	No	Yes	Yes	No	No
Canada	No	Yes	Yes/no*	Yes/no*	Yes/no*	Yes/no*	No	No
Finland	No	Yes	No	No	Yes	Yes	Yes	Yes
Denmark	No	Yes	No	No	Yes	Yes	No	No
Switzerland	Yes	Yes	Yes	Yes	Yes/no*	Yes	No	No
Estonia	No	Yes	No	Yes	Yes	Yes	Yes	No
Japan	No	Yes	No	Yes	No	Yes	No	Yes
New Zealand	Yes	Yes	Yes	No	Yes	Yes/no*	Yes	No
Luxembourg	TBD	Yes	Yes	TBD	Yes	Yes	No	No
Malta	Yes	Yes	Yes	TBD	Yes	Yes	TBD	TBD

Where “Yes/no” is used, the organisation conducts work in these areas (such as governance, education, trans-inclusion policy) but is not specifically mandated to monitor compliance to a code in the way they are for anti-doping.

No single NIB is active in all the described integrity areas, however Australia, Switzerland, New Zealand and Malta each have a very broad mandate/scope.

There are some areas in which all NIBs are active, namely anti-doping and safe sport. Moreover, nearly all address issues of sport competition manipulation, with many NIBs fulfilling a central role in the National Platform (a national organisation dedicated to the co-ordination of the fight against competition manipulation at national level , as described in the Macolin convention.

One ambiguity arose in the case of Canada, where it seems that more than one entity (the NIB and another non-governmental organisation) provide services in the domains of equality, inclusion, diversity (EID); good governance; sport competition manipulation; and safe sport.

Only half of the NIBs are active in the anti-corruption space, which is at odds with the effort made in the International Partnership Against Corruption in Sport (IPACS) to be much more active in this area.

Two topics added through an “other” category are not included in the above table because of their low prevalence.

“Improper use of drugs & medicine” was mentioned by 1 NIB as being part of their mandate.
“Spectator violence” (for example, the Saint-Denis Convention on safety and security at sport events), was mentioned by 2 NIBs as being part of their mandate.

Governance: legislation

It is noteworthy that some of the integrity issues the NIB does not have a (clear) mandate to work in that area, but they nonetheless are active in those areas by providing support and expertise to other organisations with the relevant mandate. Also some proactively look into reports made in an area they have no formal mandate in, and provide those who have with their initial findings so they can take over.

A key point is the existence of legislation to give authority and power to the mandate of an NIB. Most NIBs did not have it. Thus:

“For this organisation, being grounded in legislation I think would be far more helpful for us and something that we would… will be pushing for. So the model that we have lived with served a great purpose. I describe it as kind of, you know, [NIB] 1.0 type of thing, but we’re out of place now with the variety of issues we’re dealing with, the severity of those issues and the need to be able to have the appropriate authority that this, that we need and ability to work with other agencies, having an act passed that says that and identifies this organisation. To do that I think is critical. I don’t know whether it’ll happen, but I do think it’s critical.”

– Participant 2

Another answered in a similar vein:

“the challenge that we have had and probably continue to have is as much as we have a broader mandate than anti-doping. It’s not. Crystallised there, it’s not made concrete in a meaningful way, whereas our anti-doping mandate is through the UNESCO Convention and the Government of [nation] ratification of that convention.”

– Participant 2

They continued later in the interview to cement the view of the importance of legislation to support their work, in contrast with their perception of the Australian example:

“As much as there isn’t legislation, it’s clear the government has a responsibility to implement the Code in [nation], and they do that through our organisation. The other issues that we deal with we essentially are trying to do on our own in ways that provide value and help the sport community, but there’s no stick to that. There’s no mandate, official mandate, to us to be able to do that. So we’ve had some success as far as working with sport organisations around values based initiatives at Community level around competition, manipulation and the work that we’ve done with heal in the past around just trying to bring people together to inform them about these issues and then to create programmes and services that they might find interesting.”

“But our biggest challenge has been kind of the lack of… a real creep mandate that says you deal with this as an organisation. Like if I compare [nation] as an example where that’s really clear, right, as a government agency, this is what you do. We like that. So as far as like pros and cons and kind of things that to share with you that is number one where I think that’s a bit a real challenge for us.”

– Participant 2

Finally, all interviewees expressed the necessity of operational independence whilst acknowledging financial dependency. This would go some way to combating actual conflicts of interest but also perceptions thereof.

“We said independence is important, [so too is] sufficient funding. Having the right legal base and structures in in order to be able to actually, and that’s something we should talk about as well because there’s some limitations to that as well. But the… so [is] having setting up the right entity (sic) is really important if you actually want to deal with this and then there was. As I said, a couple of stakeholders, athletes and the and the sports studies organisation, they pointed towards us. We didn’t point toward ourselves. We just said, well, these principles are important then.”

– Participant 10

Governance: finance

Another NIB relates the necessity of legislation with funding:

“Answering the hearing (…) We said independence is important, sufficient funding. Having the right legal base and structures in in order to be able to actually, and that’s something we should talk about as well because there’s some limitations to that as well. But then so [is] having …setting up the right entity.”

– Participant 10

They continued:

“Another structural limitation to this as to how this law was made. But it’s in regards of problems related to lack of independence is that it’s team [nation] who has to do the control with the money they support these different environments. Then they have to hey, check what’s going on in these environments. Is everything OK? But the problem is… so we had to make this this agreement with them that that the law says that when there’s the separate function has investigated (sic).

“It has to hand it over to the Board of Team [nation], who then have to decide the sanctions, possible sanctions and the ‘cause they they’re the ones supporting with money. So I guess the only thing they can do is stop supporting that particular federation with money, or maybe say to them get rid of this person, or else probably… But we have this… it’s still to be seen what the possible sanctions will be if they’re… if they’re this situation will arise at some stage (sic). So that’s kind of … independence limitation. And also there’s another there’s a less strong mandate because we are, we are obliged to … to investigate incidents.”

– Participant 10

Again, as in the authority / mandate discussion above, there is a sense of perception. One notable exception to the view that legislative powers (notably in relation to investigations) was necessary.

“The interest of police is to catch this organised crime guys (sic) and this is this is good for us because we don’t solve this problem of one or second or third sports but we [don’t] solve the problem of economic crime”

– Participant 1

Governance: powers

A crucial consideration then is the extent to which powers that for example an LEA might have in relation to the economic crimes related to SCM, are mirrored across other integrity threats such as physical violence by coaches. Here the picture is, to be frank, messy. There are many, and complex, sets of arrangements. Only Australia appeared to have powers to investigate alleged criminal activity. Others found themselves moving between sport organisations’ disciplinary structures (in some cases they have a kind of sovereignty over this due to the development of a national sport integrity code), while others had limited data sharing practices with LEAs.

One participant expressed their abilities, framing themselves as a service provider to support the NSC. They appear satisfied with the more limited tasks associated with NIBs:

“We have to make an assessment and then put forward our assessment and our sort of… [what we] do is in, in our opinion, is there a violation of the ethical code or not? And then [name] board, they 100% determine whether they want to, whether they agree, and whether they want to follow up with sanctions or not. So we only, you could say we are a service provider. [It] is a term that’s sometimes used in the answer [to] doping. We are on a contract. We investigate this thing, we hand it over to them and it’s all up to them. It’s all up to them. So we just, by contract, help them out with doing an assessment.

“I think there’s so many synergies in in the way you work with these matters that a whole lot of different matters would make sense to integrate in the same function, (…) to have the trust of the environment. The vicinities from working with, for example, education and investigation, talking to the environment, working with information from these environments. Processing cases, procedures dealing with very sensitive and confidential stuff. In this context, so I think matrixing and anti-doping and the whole safe sport thing which we talk about right now is, is, is good … It’s a good combination. I think the whole, you asked some states about diversity discrimination that that could be racism or sexual orientation or whatever, those are relevant.”

– Participant 10

Question 9

D. Operational elements of the NIB

Accepted Answer

Triage

The authority or mandate of our NIBs determined which entities could engage in what processes. This was nuanced by NIBs in a form of triage.

It is clear from the range of open consultations following integrity crises/scandals (e.g. UK Whyte Review) that a deluge of responses could be predicted. A proper concern of any NIB is to manage not only the expectations surrounding the public announcement of their (potential) establishment, but the actual number of cases. This was done in response to a number of issues, such as timing and severity.

For example, any NIB would have to consider whether it was open to historic cases, and how far back these might go. This would be necessary not only for the existence and reliability of evidentiary sources, but also in terms of expectations and resource constraints. Thus, for example, when UK Sport set up its own ‘sport culture’-related disciplinary proceedings, it mandated that it would only take live cases from the date of its commencement of operations and set aside earlier allegations of misconduct. This has the benefit of controlling the flow of disclosures, but seems unjust to those who may have suffered when no such processes were in place, or when such processes of disclosure were conducted ‘in-house’, where the possibility of anonymity was not guaranteed.

Some of the NIBs report that they have sophisticated processes to determine the severity, and necessary courses of action following reporting disclosures or whistleblowing procedures. All NIBs had some form of triaging. Notwithstanding this, several respondents acknowledged their NIB’s lack of clear or precise procedures. In a limited number, but especially in relation to issues that may be broadly defined as “misconduct” (i.e. personal integrity breaches or failings), the triage systems used vague concepts like “unacceptable behaviour” or “serious misconduct” as a ‘red line’, to trigger actions of one kind or another. Typically, such a determination would initially trigger NIB investigations; equally they might trigger immediate handover to law enforcement agencies (LEAs).

As is often noted, the challenges of handover of sensitive data from private to public bodies is typically a one-way communication. The extent to which federation or NIB proceedings were (temporarily or permanently) halted or ceased was a clear concern to the NIB respondents. So too was the failure to cooperate meaningfully with LEAs, as was the perceived failure – in most cases – of an LEA to prioritise sport-related misconduct.

Only Australia appeared to have a mandated relationship with LEAs and appropriate powers, but these appeared dependent on clearer definitions and pathways, as is highlighted on the Sport Integrity Australia website (as accessed 11 April 2024). This can be thought of as best practice, though use of this label comes with an appropriate caution as to political steer, policing culture, and other national variables.

Nevertheless, it is worth observing their statement around Sport Integrity Australia’s intelligence function:

Sport Integrity Australia Annual Report 2020-21

[Sport Integrity Australia’s] intelligence:

informs and influences strategic planning and operational priorities
provides advice to the executive on operational issues of high complexity and/or sensitivity
informs anti-doping testing programs
provides insights and analytical support to investigations, legal matters and the handling of integrity-related complaints
identifies education and engagement opportunities, so as to inform priorities and planning
contributes towards a greater understanding of the wider threat environment, so as to inform sport integrity policy-making

Source: Australian Government transparency portal (accessed April 2024).

Finally, part of the success of the triage system rested on the appointment of persons with a necessarily broad set of expertise. This represented a significant challenge. As one respondent put it:

“we have investigators as well. Former law enforcement people. And also they are very focused on the on the data which is their expertise. And the non-betting related manipulation they kind of miss ‘cause. There’s a whole lot of non-betting related in sport. So that’s kind of a blind spot for them.”

– Participant 10

A similar point had already been raised about the need to be mindful of the different contexts of integrity threats, and the requirements or needs in particular of disclosures and complaints within those threats.

Question 10

E. Outcomes of the NIB to date

Accepted Answer

The outcomes of the NIB that respondents highlighted for themselves varied. Some comments were negative, highlighting barriers to effective and efficient operations, though most found it easy to list out positive outcomes.

SCM, political and LEA collaboration

The perceived negativity around concerted action centred on SCM, especially betting related sport integrity, is likely to be a function of challenges around cooperation with LEAs.

There is of course a political dimension: not all of the countries represented in the sample were signatories to the Macolin convention (see table 2 below), while none except Switzerland had ratified it.

Table 2: Signatures and ratifications of the Macolin Convention from sample

Nation	Signed	Ratified
Australia	Yes	No
Canada	No	No
Finland	Yes	No
Denmark	Yes	No
Switzerland	Yes	Yes
Estonia	Yes	No
Japan	No	No
New Zealand	No	No
Luxembourg	Yes	No
Malta	No	No

Even those that were signatories were not universal in their praise of the workings of the Group of Copenhagen (GOC), the Advisory Group of the Macolin Convention (also called the Network of National Platforms). One participant remarked:

“I have to say I’m bit disappointed for that international network. Nothing has really happened.”

– Participant 3

Others focused more on the challenges presented by the betting industry and the relevant national regulator.

A further point arising from the challenges of collaboration related to the culture and capabilities of the different stakeholders who were supposed to work together. It was widely perceived that NIBs required a holistic set of capabilities, as opposed to their perception that someone working solely on SCM within an LEA had a distinct law enforcement mentality. The following remark is representative:

“The gambling authority, their focus why they focus as they do, I think that’s what that’s like their … their … their competence. So that’s why they’re focused so. So if you’re educated on using a hammer, rather than [pause] you use a hammer and then you maybe you … you … you miss some of the other perspectives maybe.”

– Participant 10

When pushed, the respondent agreed to the more prosaic conclusion that to proficient hammer-users, everything looks like a nail. This ironic remark underscores a critical point about the competencies of persons engaged in different stages of operational work, but also as to the broad skill set and awareness needed in leadership of NIBs.

If collaboration with LEA was seen as a barrier or threat to the effective and efficient functioning of the NIB by many respondents, there were others who felt their operational independence from sports all owed them to appoint a skills-based board and move away from one dominated by sports stakeholder representation. This, they felt, allowed them to work more collaboratively in relation to SCM. In this respect it is worth quoting at length one respondent whose NIB emerged from an NADO:

“On the positive, I would say one of the really big wins was as I mentioned and that is that some years ago that was all the way back in 2014 when there was being there was being made a … a rather big assessment of the whole sporting area and how to work with that. And there was (sic) made these structural changes that our board was set up in a different way. There was a skill-appointed board instead of ‘we’re having all this, the sport in our board …’ where sometimes it was more sport interests being represented in entertainment than my sport. Instead of being anti-doping purposes. So that was like an independence thing and we worked of course behind the behind the scene in order to work with these independence measures.

“There was some money streams which was directed directly to us instead of through the sport organisations as well and probably most importantly. Our funding was raised [in the ] course of three or four years (…) So that I would, I would say that that’s been one important thing then also.

I’ll say being able to … despite to say something positive about the match-fixing area, or I could say a whole lot of other stuff about the anti-doping area but trying to move on to some of the other areas … and probably also some more, some new examples in the [nation] doping area, but anyhow in the match-fixing now, despite all the limitations. …

“As to the platform work, I think we’ve been able to create the … a positive outset in in order to actually work with this area of work to gather the relevant stakeholders and to …to some extent contribute to the international work as well, and then we probably just struggling a bit more on a national level, but to somehow contribute to that and being part of international groups on the match-fixing area as well.”

–Participant 10

The respondent linked this operational independence to greater positive perceptions from athletes:

“Being pointed towards having athletes trust and having both the political system pointing towards them [the athlete body] to doing them … actually begin[ning] with being the secretariat function of the metrics and platform, and also having athletes pointing towards us in order to have trust with our when they’re dealing with unacceptable behaviour. That’s something we really happy about that that the sport environments in, in particular athletes, they support us working in this area.”

– Participant 10

An example of such support is captured by another respondent who is clear that the independence of the NIB is a key element of athlete stakeholder buy-in:

“They just said that’s the key here … is that you have to have someone where people can go that isn’t their national sporting organisation.”

– Participant 8

In such a manner conflicts of interest (or at least perceptions thereof) are minimised while enhancing trust with the NIB.

Relationships

It was absolutely clear that the building of relationships among stakeholders was universally thought to be crucial. This arose at different levels. Specifically in relation to authority/mandate and operational levels first between the various ministries involved. The range of ministries included culture, education, health, sport, and technology.

Thereafter, the relations to national federation (NF) stakeholders was critical for buy-in to the concept of an NIB. In addition, in most but not all countries, the NOC played a decisive role in integrity operations maintenance (not least of all because of the levers that they may have in relation to Olympic participation). In one case the national Paralympic committee was also noted, but this was not as critical a stakeholder in general.

Finally, the athletes themselves represent the most important stakeholder to consult with.

Several NIBs noted that their previously existing support of NADOs made this transition easier, because a considerable degree of trust had been developed. This point must be nuanced. In more than one interview, the respondent made clear that the “philosophy” of the NADO was critical. Their being perceived of by athletes as a quasi-police force (in compliance and sanction mode) sat uneasily with their role as advocate, or at least active listener and counsellor to those reporting integrity breaches in relation to safe sport (including safe workplaces).

One key message that athletes had also sent was that they preferred a “one-stop shop” where all integrity practices and regulations could be found.

This point slides easily into the question around how the integrity body should be formed. There were really only 2 options presented.

‘de novo’ (starting from the beginning - a new approach), fitting around existing structures, stakeholders, and practices (preferred by 3 out of 10 participants)
developing out of the pre-existing NADO (preferred by 7 out of 10 participants)

Most NIBs referred to the obvious benefits of building on existing structures, citing economic savings, efficiency and continuity as key positive drivers. The following was the most extensive comment, but was typical of responses to the issue:

“The number one thing that I would consider in the UK as you think about this is the credibility of the anti-doping agency that you have. And athletes’ perceptions of that organisation. I think we’re a bit beyond that now, but rewind a year or so you would have a very similar response from sport organisations. This is a power grab. You want more budget, you want to grow yourself, be an empire, all of those things.

“What we’ve heard from athletes, the people who are coming forward, concerned about maltreatment and sport demanding change was that there is an organisation that deals with anti-doping that is trustworthy, that we have confidence in that we can if we share information with them, we know that they’re going to act on it…I can’t say that, you know, that that’s every athlete just saying that…there’s when I think a quick wins there the athletes were different than the sport organisations but the sport organisations are part of the problem, so that you know very clearly there is a concern there around, you know what steps are going to be put in place to investigate. The toxic culture and sport.”

– Participant 2

It is important to note that there are 2 drivers here, not 1. The first is clearly the point about building on structures, while the second is building on trust. In the latter case, the NIB representatives were clearly sceptical.

While in one case an NIB saw themselves as a service provider to sport federations or the NSC, another NIB – that performed very similar functions - remarked:

“In some cases we are not pleased and we are, how should I say, we are a bit worried when we send it back to sport federations, because we know that there are a lot of … there are … the rules are not as good they should be. There are conflicts of interest because especially in small sports they are same people in sport clubs and same people in sport for the races, and they don’t have (… ) disciplinary rules. They are not OK and disciplinary board are not as independent that they should be. It’s still a big problem. I think it’s it has come a bit better but it it’s not as good it should be. It’s not good situation and that’s why I think that we might [improve], or at least I personally I hope that.”

– Participant 3

Finally, though mentioned only specifically by 2 of the respondents, the role of the media in bringing pressure to bear on non-compliant (or plain) rogue actors or institutions was noted. This tended, however, to be in the establishment stages and acting as a further catalyst. The skilful marshalling of the media was seen as a key tactic for the NIB.

As noted above, in all cases, it was noted that crises or scandals were the driver for political change. It was also noted that the reality of working with multiple ministers was a challenge to effective practice. We will return to these points in the conclusion.

Development of a national framework/code

A consistent point made was that consultation was critical for the successful development of the code, but also its successful adoption and implementation. This point is a staple of good governance, where many (sport) organisations in the past had simply commissioned external companies to develop vision and mission statements as well as regulatory practices.

Interviewer:

“So you go by the rules that the sport has made. Is that how you do it?”

Participant 7:

“Actually the uh, the each sports organisation (sic) have their own regulation and what is wrong or misconduct so…. so each sports federations have their own definition of the misconduct.”

To a similar prompt another responded:

“Also to have a common disciplinary …common rules of common procedures. Some of them have done it, but not too much … which are not adopted yet in in all federations, but basically we have announced … and given rules in like guidelines like … guidelines for the sport federations.”

– Participant 1

One NIB was clear that this differentiated approach was inadequate and implemented a national code:

“So you know, a particular incident might, might, might all the way be tracked back to good governance, but might involve you know, sideline behaviour of people who aren’t involved in a sport and it might involve bad coach reaction and it might involve player behaviours. … All of that sort of activity has largely just been left to each sport to make it up its own rules. Now football, for example, may have quite comprehensive rules. Weightlifting may have not. So what we’re trying to do there is to actually say to those sports, if you’re going to adopt our code, we need to see that you’re actually having some systems in place.”

– Participant 8

But where to assign different threats? The first part of the above quotation shows how the threats themselves do not come in hermetically sealed boxes. This would be a challenge for an NIB, but where an NIB does not have a mandate for all those integrity threats it gets more complicated. As another respondent remarked:

“the racism is a form of maltreatment and would potentially be picked up under the safe sport piece which is administered by a different organisation.”

– Participant 2

Nevertheless, they had a vision to systematise this, in some cases based on international rather than a national system:

“You would have mandatory codes or policies, whatever you want to call them, that all of our sporting organisations would be required to adhere to that are administered by an independent sport integrity agency. [For] us to be able to do that on behalf of sport and currently I think I see kind of five things that fall in there. They’re not perfect, but the way I view it is they kind of work. In my mind, there’s the world Anti-Doping code and your implementation of that. There’s the Macolin Convention or the [International Olympic Committee] CS code on the prevention of competition manipulation and your implementation of that. Sport and in [nation] we have developed [a code] for [safe sport], which defines prohibited conduct. It defines the behaviours that are not allowed and it sets out the rules for how to investigate them, what people have to consent to, all the things we’ve talked about.”

– Participant 2

Different NIBs are in different stages of development. Some, like Switzerland, have used the NOC and NSC as vehicles to establish a national code universally, others like Australia have achieved a national integrity framework, whereas others are in the process of attempting to gain such universality. The existence of such is clearly an integral part of the operationalisation of the NIB.

Operational matters

With regard to the range of broad integrity issues in sport, there are many similar processes, such as establishing mechanisms for disclosure or reporting, investigating, and establishing adjudication or dispute resolution processes.

Equally, there are considerable overlaps in approaches to awareness-raising and education based on alignment (or compliance) with value-based frameworks.

Equally, of course, the key stakeholders remain constant over the different integrity threats, with few variations. It is clear that significant potential synergies and savings exist in the coordination of these activities, and many respondents reported such efficiencies.

The bringing together of these was not without its challenges though. One response is worth quoting at length, in relation to personnel being ill-equipped to investigate certain other potential integrity breaches:

“… they’ve just probably demonstrated lack of competence in actually investigating because they only have legal people as well. So they haven’t really been able to actually investigate from our point of view, and also probably been less keen than we would be, and having less professional procedures for actually how to work with how do we approach these ‘cause if you don’t have investigative experience, that would be a huge problem as how do we see it?”

– Participant 10

Moreover, when this line of questioning was put to another respondent the question was posed: “Do you find that different when it comes to issues of abuse, maltreatment, exploitation, sex offences?” and the respondent answered:

“I think so. I think so for sure. And as I say, competition manipulation, those two things, I think they’re there’s far more openness to work with an independent body and to be seen to be; more so than anti-doping anyway.”

– Participant 2

Notwithstanding these differences, all expressed sufficient overlap so as to produce consistencies of practices, shared learnings, operational economies and efficiencies – not least of all in terms of education.

On being asked “do you genuinely think a ‘one-stop shop’ for athletes where they had one place to report to and a variety of heads of the different integrity threats in one overarching institution, do you really think that’s the way forward? And if so, how do you see that working?”, one participant remarked powerfully:

“Well, I do. When we’ve given it a lot of thought from a number of different perspectives. So, firstly, it the issues are similar in nature and the responses to those issues both from an operational perspective as well as kind of a root-cause analysis, cultural perspective. Make[s] a lot of sense. So if you tackle integrity issues through the lens of ‘there needs to be a code, there needs to be certain requirements, there needs to be investigative capabilities, there needs to be needs to be education, there needs to be needs to be sanctioning’. I mean those are the core components of the WADA code. Those are the core components of the response to competition manipulation. Those are the core components of dealing with safe sport. Potentially they’re the core components dealing with governance-related matters within a sport organisation. It’s very similar, so being able to put those things into one organisation allows for a lot of efficiencies and the issues aren’t necessarily exclusive of one another. So they kind of cross them. So I think there’s a lot of value there. I think as we talked about before.

“Secondly the causes of these issues are all quite similar - that it’s about a lack of values within the sports system that’s driving unethical conduct, and that is allowing it to happen. And therefore being, having, an organisation that’s able to deal with those root-cause analysis across all of those issues super important. So I think that also adds a tonne of value.

“I think there’s an efficiency argument as well, from a government perspective at least, in X that multiple organisations cost a lot more money. So you really want to make sure there’s a need for it if there will be different organisations dealing with different things in different ways. So that was an issue that we were focused on… is… we’re kind of in a place where we’re looking to bring things together more so than pull them apart, from an efficiency point of view. So the analysis that we’ve done, it’s kind of suggested that [it] makes far more sense.

“The external relationships that you need to have to deal with these issues. Again, pretty similar, so having one organisation be able to deal with other organisations related to all of these makes a lot of sense, frankly. So that all holds together […] well. So that’s kind of where we’ve got to, but the downside with it though that I would say is - what we’re hearing from athletes is - that they would, they would far prefer a ‘one-stop shop’. If this notion of ‘I’ve got to do an e-learning programme for you and one for you and one for you and one for you’. And ‘I’ve got to sign this form and you want my whereabouts and you want this’. As opposed to it all being wrapped and up into one integrity programme and I deal with this organisation and that’s quite helpful.”

– Participant 2

Equally, others highlighted different “philosophies” of integrity management, ranging from advocacy to counselling, compliance-sanctioning, and restorative justice. These all relate back to issues discussed, such as the consultation over processes leading to the codification of rules. This is captured excellently in the following quotation for which there was almost unequivocal support:

“The key reasons to be honest that they [sports] want to sign up and they are supportive and behind it is that it brings, I guess it brings that minimum standard. It makes it really clear and it brings consistency. …Depending on how implementation and adoption processes land would, [it would] take the … thinking out of it for the sports, that you know there’s easily obtainable information about how to set up policies. And an investigation is also a possibility, you know, which could be the mediation could be either into that probably….. And based on a restorative approach. So it’s not sort of ‘ambulance at the bottom of the cliff’ but aiming to resolve as many things up-front … and as close to inception as possible.”

– Participant 8

This point follows directly on from those in authority, mandate, and triage system. Establishing clear understandings of how normative labels (such as “serious” and “criminal”) are to be operationalised at different stages of the process was critical for clarity and consistency.

We noted how the problem for historic cases is in need of serious consideration. Yet it is also worth considering the range of responses that are not tied to regulatory applications. In some cases, NIBs in relation to (for example) anti-doping advertised counselling services on their web pages (such as on Anti-Doping Denmark’s web page (accessed 13 April 2024)).

Another respondent noted that not all victims / survivors are seeking “their day in court” (or a hearing of whatever kind), but rather wanted simply to be heard:

“He heard about that [the evolution of the NIB and the possibility for historic disclosure] and he’s never told anyone before and he just wanted to tell someone. And that was it.”

– Participant 5

They went on to remark:

“So in these historic, I [call] them historic, even though they may not be that old, we … we do exactly that because we don’t want to say ‘oh, we don’t care, it’s out of our remit, off you go’. We want to … to … to signal them that, you know, to support them, as well to say look unfortunately it’s the … the rules are what they are is … is not by … by date the statute of ethics wasn’t in place at the time so therefore. It wouldn’t necessarily …be possible for us to go to take it through the procedure. But looking at the at the case with today’s rules and regulation, it would very likely represent a violation of the code of ethics.

“So sometimes that’s something that’s helpful for the individuals and the sporting organisations, because they can then do whatever they can within their own possibilities. And sometimes for the victims we’ve had cases where you know it, it just it is what it is. But they were kind of happy to hear from an external independent organisation ‘OK, it is wrong, what happened to me’. And sometimes that’s just it. That’s also something - even though it may be it’s not nice to say that ‘OK I can’t really […] it’s wrong what happened to you but can’t do anything about it’ - but … sometimes it’s … I’m quite surprised, [I] was quite surprised to hear that they are still, you know, it’s OK for them. It’s a good reply that they receive. You know what I mean? Rather than just ‘we’re not dealing with this’.”

– Participant 5

Human and financial resources

Funding in general is seen as an obstacle to effective functioning of the NIB. The massive disparities in international funding mirror those of UK national funding, as reported by McNamee et al (2020).

Table 3: FTE and operating budget

Nation	People (excluding DCOs)	FTE (excluding DCOs)	Doping Control Officers (DCOs)	Annual budget (equivalent GBP)	Comments
Australia	158	150	N/A	£34.4 million
Canada	50	45	70	£5.9 million
Finland	15	15	25	£2.8 million
Denmark	18	17	8	£3.5 million
Switzerland	47	36	31	£6.5 million
Estonia	8	8	N/A	N/A
Japan	14	12.6	20	N/A	20 independent experts
New Zealand	24	23.6	N/A	£2.6 million	This is the situation as-is, just for the NADO. Expected growth to 45-50 FTE.
Luxembourg	3	3	N/A	N/A	This is the situation as-is, just for the NADO.
Malta	TBD	TBD	TBD	TBD

The sharing of data is vital but complex in the work of NIBs. Formulation of a standardised instrument (e.g. a code of ethics) and associated practices are critical. In the area of anti-doping, the mandate is clearly written down the WADA’s World Anti-Doping Code (WADC) along with its 7 International Standards, supported by various conventions.

For other integrity areas this is not the case, and that leads to haziness. Not all respondents were entirely clear on the limits of their powers to share data.

Difficulties in data-sharing were almost always reported as an obstacle and in particular with or by LEAs. This was linked with the mandate issuing appropriate powers:

“But our biggest challenge has been kind of the lack of… a real creep mandate that says you deal with this as an organisation. Like if I compare [nation] as an example where that’s really clear, right, as a government agency, this is what you do. We like that. So as far as like pros and cons and kind of things that to share with you that is number one where I think that’s a bit a real challenge for us.”

– Participant 2

Yet they, along with some other NIBs, appear to have some data sharing agreements or practices at least. Thus:

“So if I call and I say, look, I’m really concerned that, you know, somebody’s fixing a match, we have the authority to be able to investigate that based on the contract that we have with the sport organisation that says that we’re administering these rules on your behalf, right? Then you get someone who calls and says I’m really concerned because this coach is doing something I really don’t like or whatever it might be. The challenge we have there is: we have no authority over that individual to be able to do anything, so we don’t have a set of rules. We don’t administer those rules, so to be able to then proceed to do something becomes more challenging. So we can push that particular issue to the [specified organisation], who’s currently administering Safe Sport and they can investigate and look into it, or if it’s an issue that falls outside of that it would be deferred back to the sport organisation, essentially to deal with depending on what that issue might be and how they go about dealing with it.”

– Participant 2

Not only the ability to share information with external stakeholders such as LEAs is relevant. Sharing information within the NIB can also be relevant, considering the interconnectedness of many integrity issues. Specifically in the space of sport competition manipulation (SCM), 7 out of 10 of the NIBs in the sample also hold (part of) the functions of the National Platform for SCM.

Thus, depending on the (legal) bases for the NIB, data can in some cases be shared within the NIB for other purposes than SCM (e.g. for sharing data of known violent sport spectators, or those with a history of sexual predation). This will, however, depend on the specifics of the mandate given along with prevailing data protection rules and regulations, in particular those pertaining to the limits extant in each national context (what are sometimes referred to as “purpose-limitations”).

Finally, with respect to data-sharing in relation to the establishment of a NIB rather than its operations, one respondent noted at length their open attitude to sharing experience:

“You know, there there’s a huge interest from … from various parties and … and every … every country is in a very different stage, some they’ve got established agencies, others are only starting to think about how to set up something like that. We as a [nation] integrity we’ve …we’ve had like quite a rough start.

“This is probably not the right way to put it, but it … it was like there was huge pressure and we … we started within [a short time period] to … to set up everything. And now we we’re … we’re kind of getting a little bit more experience, we know it’s … it’s difficult if you’re in that situation and we are therefore very happy to help. Very happy to share the … the small amount of … of wisdom and knowledge that we have acquired over the last two years, to share that with anyone that’s innocent really. So we’re more than happy, no issues whatsoever.”

– Participant 5

We will return to this point in our conclusions.

Codes

One critical element of perceived success was the presence of a national code for misconduct. Not all countries surveyed had such a code. Moreover, these were identifiable under a variety of names, most of which are in the public domain.

Codes of misconduct

All thought it was exceptionally important but equally exceptionally difficult to develop. As one participant remarked:

“That’s a huge challenge.”

– Participant 10

Others have managed it or are in the process of developing such. Australia has such a code (the National Integrity Framework), and New Zealand shared a pre-final draft of their code with the authors.

Several participants referred to codes that were the product of each national federation.

In at least 2 countries, investigations were conducted within the purview of a set of sport-specific regulations. It was widely acknowledged that not only does this open the door to inconsistency, it is inefficient. Investigators must become accustomed to the heterogeneity of rules that apply across the sport spectrum.

Worse, in some cases the investigation’s reports (because of the codes’ specification) went back to the national federation to be heard as disciplinary cases. When, therefore, members in positions of authority were the object of disclosures, there was the immediate and serious potential for such cases to create deep conflicts of interest (and not merely perceptions thereof).

One participant remarked at length:

“They just said that’s the key here - is that you have to have someone where people can go that isn’t their national sporting organisation. What we have in X, though we have in sport Y. An entity that is still fundamentally responsible for the leadership of sport, if you like, and the guardianship of sport, and one of the core roles is to build capacity and capability within sport. But the real [challenge], if we look at the sort of areas where we have had most controversy and public comment in the last 7 to 8 to 10 years, so that gives us the mandate, [is] to set minimum standards.”

– Participant 8

A crucial element of any mandate of an NIB appears to be its relation to the sport governing bodies (SGBs), including codification of minimal standards and / or expectations.

Education

In recent years there has been a significant policy shift in anti-doping towards greater focus on educational interventions. One respondent went as far to say:

“That’s our number one priority, is (sic) educating and changing culture.”

– Participant 6

They also acknowledged that the shift to emphasise education brought other benefits in athlete buy-in:

“So the more we’ve shifted into education, perceptions changed a lot more that we’re there to actually help athletes and go after cheats (…) So we sort of build it off that trust.”

– Participant 6

Another respondent remarked similarly about the promotion of educational practices to build stronger relationships:

“This is abuse of children in sports, sports, our national heritage in [nation], [do] we really want to go down the path? So the more we’ve shifted into education, perceptions changed a lot more that we’re there to actually help athletes and go after cheats.”

– Participant 2

Equally, another emphasised education thus:

“So don’t forget education would be the other lesson. And from the very, very, very beginning, education is so, so important. I know everyone says that, but we’ve literally experienced [it]. What happened is you if you don’t do it from day one, if you don’t integrate it as an integral part of whatever you want to do in sport integrity, you need to be… that then needs to be a focus on education as well.”

– Participant 5

Many of the respondents recognised the overarching importance of education, not simply in terms of promoting good practices, raising awareness of regulations and sanctions, but crucially in building relationships while driving economies of scale, and efficiency across the integrity threats. One respondent noted this was part of partnership-building with sports, especially less commercial ones, where the NIB ability to provide education meant financial savings for the NGBs themselves.

While many of the more commercial sports had developed their own educational and regulatory practices, nearly all small-to-medium sports (however calibrated) were said to welcome the offer of utilising free resources and receiving support for experts at the NIB. There is, for example, significant scholarship in the effectiveness of anti-doping educational interventions. Whereas in other integrity threats (such as SCM), the educational programmes are in their infancy, and there is no established peer-reviewed literature to draw on in terms of guiding those who design such programmes, nor is there any literature on the evaluation (good or bad) of these programmes. In addition, good practice from anti-doping education (for example), could be modified ‘mutatis mutandis’ (with the necessary changes made) to apply to other integrity threats.

One respondent lamented the lack of coordination of educational activities:

“Prevention work - we are not taking care of prevention and in [nation] there’s at least at least half a dozen organisation (sic) who are doing it, educating and things like that in the safe sport, and that’s not easy. We haven’t been able to tackle that problem in [nation].”

– Participant 3

A summary point here, then, is that a broad integrity education was universally supported in the sample. It was clear that respondents perceived that efforts directed to education had multiple positive benefits beyond compliance with international federation regulations (e.g. with anti-doping) or sport stakeholder interests (such as alignment with non-manipulated sport competitions), and can be used as a trust developer with athlete stakeholders and an economy-driver for sport

Question 11

Conclusions and recommendations

Accepted Answer

Conclusions

What can be learned from the data collected in this research is difficult both to generalise and meaningfully apply. The data gathered from the questionnaire and interviews must be understood first and foremost in its own context. Across each nation surveyed there are differences, and to a lesser extent similarities, in legal systems, public policy commitments, political priorities, sport systems, and sports cultures. There is also the unique trajectory each nation has in relation to the myriad crises and scandals it has had in certain sports in their respective recent histories. The Appendices contain more information on specific NIBs (including country factsheets), partly as a product of the responses to the questionnaire and partly from further online desk research.

Consideration must also be made of the glut of crises and scandals in the last 20 years or so that forms the global backdrop to NIB developments and clearly have also had a substantial, if hard to quantify, influence on national-level responses.

Nevertheless, it is undeniable that the move toward national sport integrity bodies is on the rise and is unlikely to be reversed. When the research was originally commissioned the researchers were asked to include as a minimum the following 7 countries: Australia, Austria, Canada, Denmark, Finland, New Zealand, and Switzerland.

Not long after commencement of the research it was clear that others were already in operation and ought to be included in the sample (Estonia and Malta), and Luxembourg had also had its NIB mandated by its government. They were thus added to the study. In the course of the study it also became clear that Lithuania, the Netherlands and, to a lesser extent, Singapore, had also developed plans for such a body but that their lack of detailed development meant that they did not warrant inclusion in the sample. It may be concluded that the general policy movement is global.

This has also to be seen against the substantial efforts of the international Olympic Committee (IOC) to invest into specific areas of integrity threats to support policy development by national Olympic committees and international federations (IFs).

DCMS had indicated in 2020 its willingness to move in this direction but through the processes of Brexit and the COVID-19 pandemic, this lost momentum. The research question set by DCMS for this report “What dedicated sport integrity organisations are in place internationally, and are there opportunities for learning to inform the UK system?” is therefore timely. Noteworthy too is the sub-question “Where a new model has been established, has this been done through legislative changes?”, since such changes were indeed strongly emphasised by the respondents in the sample. What follows are general conclusions and recommendations that spring from them.

The context of the drive towards NIBs is partly one of vast differences in responses to different crises or scandals. Some sports have embraced these developments as a catalyst for change. Examples include the Athletics Integrity Unit established in 2017 out of the former International Association of Athletics Federations (now World Athletics), the Biathlon Integrity Unit which was developed by the International Biathlon Union in 2019, the same year that International Gymnastics Federation established its own Gymnastics Ethics Foundation (2019).

Perhaps the oldest of these IF integrity bodies was established by the International Cricket Council, whose work predates the emergence of these bodies by nearly 2 decades (2000). Where there were individuals from the nations within the sample which had taken leading roles in international discussions and developments, they have transferred this learning to influence the national level with varying levels of success. Widespread support was offered for the necessity, or indeed criticality, of integrity champions with national and international (sport) political connections.

The fact that many IFs have established an integrity function according to their own needs and in response to different integrity threats (whether anti-doping, sport competition manipulation, or safe sport abuses) has had the consequence that the field is characterised by significant heterogeneity. The development of an NIB to establish co-ordinated national responses and to bring some semblance of consistency was almost inevitable. This might be thought of as a national integrity framework, and indeed this is the approach of the largest authority in the sample – Australia. New Zealand appears to be developing the same function within its soon-to-be operational National Sport Code.

Several respondents uttered the well-known political dictum that ‘one should never waste a good crisis’. Some specifically targeted both media and politicians to create and sustain political and financial momentum. Often safe sport was the catalyst for this, since it was a response to the abuse of vulnerable populations (usually children and adolescents). Here the mantra was captured in the phrase that ‘what was needed was a vision of their nation’s sport system and reputation that the public could have confidence or pride in’.

In the process towards the establishment of a NIB, one message was clearly dominant. Consultation with athlete and sport stakeholders (coaches as well as administrators) was considered critical. Another was the avoidance of ‘de novo’ (starting from the beginning) developments; clearly much can be learnt from integrity bodies – whether sport or nationally established - without planning everything from a blank slate. One respondent went as far as saying that they would metaphorically “steal” any good practice they found from any source.

On the other hand, they also observed a strong international spirit of sharing information and good practice. The development of a forum for integrity bodies at a national level in this regard has followed various recommendations from the UKAD 2020 report Mapping the Landscape of UK Sport Integrity. Moreover, a meeting held in Lausanne in March 2024 appears to have garnered widespread support in establishing such a forum led by the Australian NIB, supported by the Finnish NIB.

A further point related to financial developments. In some cases the financial investment was very substantial indeed. Yet the scale of finance should be understood against a timeline. In one event there was very substantial investment from day 1, whereas with others the upscaling of the functions and personnel was incremental. Other NIBs were more modest both in terms of initial financial outlay and overall operating scale. Some detail for these differences in quantity of finance and human resource can be found in the country factsheets (see Appendix 1).

Given that financial resource will always be a scarce good, there appeared consensus around targeting resources against public perceptions of the most problematic integrity threats. Most frequently this was safe sport, though it is acknowledged that anti-doping is consistently in the public gaze, while SCM is often uppermost in the more commercial sport stakeholders minds since it threatens the product of mediatized sport competition.

A further financial point was noted in terms of the “cost” of doing nothing. Given the role that sport often plays in national political identity and discourse, and in soft power and sport diplomacy, the point is noteworthy. At a sport level, more than one respondent talked about the costs of underwriting integrity / disciplinary hearings in substantial cases running well into the hundreds of thousands of whichever currency was applicable. A preventative rather than restorative approach was mooted, and this was often allied to enhancing integrity educational interventions.

The notion of efficiencies to be secured across the educational programmes of different integrity threats was widely supported. Often this appeared in the guise of saving sports from making unnecessary expenditure by sharing resources and developing centralised integrity education programmes. Again, this mirrored recommendations from the UKAD (2020) report. A further point, in relation to educational programmes, arose that was somewhat novel.

A key factor that was perceived by the respondents was based on the athlete perceptions of their functions. Several respondents mentioned the avoidance of being perceived as a type of police force. Where, by contrast, athletes perceived them as an educational force, greater trust was generated, since all parties were seen to be unified in the goal of protecting clean, fair, sport.

This point must, however, be nuanced. Several respondents also noted that the different integrity threats were characterised by different cultures. While a law enforcement approach to SCM might be absolutely necessary, the same mindset or ethos would be counter-intuitive in investigations and counselling processes around safe sport. Developing the right approaches and harmonising these is undoubtedly a major challenge for any NIB that has a “broad integrity” portfolio.

Without doubt, the most important single point arising from the research – and one noted by all respondents - related to the sub-question regarding the authority or mandate given by governments to the NIB. One of the NIBs has explicit legal powers to investigate and share data reciprocally with LEAs. All other NIB respondents noted that a lack of clear mandate prevented them from more effective functioning. Many noted the challenges around cooperation with LEAs. In some cases there were positive stories of cooperation, in the majority, however, there were not. The inability to share data was observed here as was the failure of LEAs to prioritise sport-related allegations and disclosures.

In some cases, the NIB merely carried out investigations, which it then passed over to sport bodies to use as they saw fit in disciplinary hearings. This was in general very negatively perceived. Most respondents spoke of real and perceived conflicts of interest which led to the (further) erosion of trust between athletes and NGBs. The importance of this point was often underscored in discussions around the operational independence of the NIB, even if it were dependent financially on government sources.

In a minority of cases, there was good cooperation between the NIB and the sport-driven disciplinary proceedings and confidence had been built up. This appeared to be the case when the NOC was strong and had utilised its own levers to generate positive momentum for integrity awareness and where necessary sanctioning. The strongest NIBs appeared to have a range of powers, some of which were anchored in legislation, with appropriate specification of definitions, regulations, and powers to sanction.

A final point concerning the establishment but also the governance of the NIBs related to the vital relationship between the NIB and the relevant ministries. While the configuration of ministries that catered for sport changed from country to country, it was clear that cross-ministry approaches supported strong NIB operations. Many respondents commented negatively on having to deal with a revolving door of (sport) ministers with whom positive relations had been developed, only to have to start again before long with a new minister. Equally, many respondents talked of the necessity of cross-ministry collaboration (most notable sport and justice) to establish the optimal authority and mandate, along with the necessary powers to function effectively. In most cases, this included a national code or framework. This, however, is not to be seen as a mere output, but rather a complex set of processes marked by high levels of consultation and cooperation across stakeholders. Without such a unified or coherent code or framework many of the positive features of NIB operations (in terms of coherence, consistency, effectiveness, efficiency, legitimation, and so on) are likely to be (fatally) undermined.

At a more concrete operational level, consensus-building with athletes and coaches was thought to generate trust and buy-in. Critical to this was the functioning of the NIB in relation to some clear and transparent triage process. Often respondents were critical of their own procedures, and reliance upon vague or underdetermined criteria and labels like “unacceptable” and “serious” behaviour or misconduct. In some cases the legal experts aligned to the NIB and the sport structure were able to agree upon their operationalisation, but this clearly leaves too much to individual interpretations.

Supporting the triage system was the perception of the need for expertise in case management in order to have consistency in approaches. Again, cooperation with LEAs played a part, as did the appointment of experts with investigatory powers. While some were critical of the “investigators’ mindset” in some integrity breaches, there was also recognition that poorly conducted investigations could hamper the entire process of integrity reporting and hearings. Part of perceptions of good practice here was indeed the need for (better) data-sharing, which would only proceed on good networks and confidence by LEAs of the quality of investigative work on the NIB.

A final point relates to extant (existing) and new sport structures. Where there was a positive relation between an NADO and its athletes and sport stakeholders, using the NADO as the organisational springboard for the NIB was positively viewed. Respondents spoke about building on years of policy development and educational practices, a clear code against which to educate or sanction, as well as referring to the obvious economies that could be enjoyed by not starting a NIB de novo (anew, ie from the beginning). Whether this is a function of bias in the sample is unclear. Though it should be noted a minority part of the sample had previous roles in anti-doping prior to their current role at the NIB. Some reflected on what these developments mean for a global standards agency such as WADA in relation to a broader integrity agency, but this is a moot point for this study.

Recommendations

Should the UK decide to establish a new NIB at any point in the future, the following points should be borne in mind.

Decision over composition of any UK-wide steering group is necessary, most likely to include Sport England, Sport Northern Ireland, Sport Scotland, Sport Wales, and UK Sport but also other major stakeholders, in order to commence discussion on mandate and associated governance.
Extensive consultation with all key stakeholders in particular athletes and coaches.
Establish consensus groups from the sport stakeholder community (decide on criteria of how best to group them according to organisational needs) over national framework.
Don’t let the perfect be the enemy of the good; the most powerful commercial sports might not buy-in at an early stage, but must be included in early consultation processes.
Consider carefully the balance between incentives and disincentives to align sports with the NIB, using political, financial and operational leverage.
Establish the NIB as sufficiently (operationally) independent.
Initial phases to be modest in scope in order to secure early adopters and progress with quick wins, with staged incremental developments planned well in advance and in alignment with national and international sport calendar.
Each stage to be outlined in advance with adequate structural funding and operational budgets.
Create a legal basis for the NIB, including clear mandate, powers, definitions, procedures from disclosure to sanctioning, and measures for sharing data.
Develop early vision and procedures for cooperative functioning with law enforcement agencies.

International comparisons of national sport integrity systems

About the Authors

Executive Summary

Introduction and context

Aim

Methods

Research ethics approval

Sample

Methodology

Data themes presentation

Data themes discussion

A. Landscape/context for NIB development

Crisis / scandal genesis

The rise of athlete-recognition

Conflicts of interest are a catalyst for change

B. Establishment of the NIB

Authority / mandate

Building on NADO structures

Political will

C. Setup and governance of the NIB

Scope

Governance: legislation

Governance: finance

Governance: powers

D. Operational elements of the NIB

Triage

E. Outcomes of the NIB to date

SCM, political and LEA collaboration

Relationships

Development of a national framework/code

Operational matters

Human and financial resources

Codes

Education

Conclusions and recommendations

Conclusions

Recommendations

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About the Authors

Executive Summary

Introduction and context

Aim

Methods

Research ethics approval

Sample

Methodology

Data themes presentation

Data themes discussion

A. Landscape/context for NIB development

Crisis / scandal genesis

The rise of athlete-recognition

Conflicts of interest are a catalyst for change

B. Establishment of the NIB

Authority / mandate

Building on NADO structures

Political will

C. Setup and governance of the NIB

Scope

Governance: legislation

Governance: finance

Governance: powers

D. Operational elements of the NIB

Triage

E. Outcomes of the NIB to date

SCM, political and LEA collaboration

Relationships

Development of a national framework/code

Operational matters

Human and financial resources

Data sharing

Codes

Education

Conclusions and recommendations

Conclusions

Recommendations

Is this page useful?

Help us improve GOV.UK

Help us improve GOV.UK