TAS - CAS 2025-A-11209

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CAS 2025/A/11209 Swansea City AFC v. Hatcham FC ARBITRAL AWARD delivered by the

COURT OF ARBITRATION FOR SPORT

sitting in the following composition:

Sole Arbitrator: Mr Lars Hilliger, Attorney-at-Law in Copenhagen, Denmark in the arbitration between Swansea City AFC, Wales Represented by Ms Liz Coley, Attorney-at-Law in London, England

Appellant and Hatcham FC, England Represented by Mr Jan Schweele, Attorney-at-Law in Lisbon, Portugal

Respondent

CAS 2025/A/11209 - page 2

I. PARTIES

1. Swansea City AFC (“Swansea” or the “Appellant”) is a professional Welsh football club affiliated with the Football Association of Wales (the “FAW”), which in turn is affiliated with the Fédération Internationale de Football Association (“FIFA”).

2. Hatcham FC (“Hatcham” or the “Respondent”) is a professional English football club affiliated with the English Football Association (the “FA”), which in turn is affiliated with FIFA.

II. FACTUAL BACKGROUND

A. Background Facts and the Appealed Decision

3. Below is a summary of the relevant facts and allegations based on the FIFA Dispute Resolution Chamber (the “FIFA DRC”) decision dated 8 January 2025 (the “Appealed

Decision”) and on the Parties’ written and oral submissions and evidence adduced. Additional facts and allegations found in the Parties’ written and oral submissions and evidence may be set out where relevant in connection with the legal discussion that follows. While the Sole Arbitrator has considered all the facts, allegations, legal arguments and evidence submitted by the Parties in the present proceedings, he refers in his Award only to the submissions and evidence he considers necessary to explain his reasoning.

4. The present dispute relates to the Appellant’s claim to set aside the Respondent’s claim for training compensation in respect of the English/Nigerian football player Wasiri Ola Williams, born on 1 April 2000, (the “Player”) during the period between 7 Nove mber 2019 and 6 October 2021 (the “Training Period”).

5. Pursuant to the Player’s player passport (the “Player Passport”) issued by the FA, the Player was registered as follows: - From 28 August 2018 to 8 November 2018, the Player was registered as an amateur with the English football club Lewisham Borough. - From 9 November 2018 to 6 September 2019, the Player was registered as an amateur with the English football club Turnbridge Wells. - From 10 September 2019 to 6 November 2019, the Player was registered as an amateur with the English football club Sheppey United. - From 7 November 2019 to 6 October 2021, the Player was registered as an amateur with the Respondent. - From 4 February 2022 to 13 June 2022, the Player was registered as an amateur with the English football club Braintree Town FC.

6. Pursuant to the information presented to the Sole Arbitrator during these proceedings, the Player played a limited number of matches (around 10) for the Respondent duringCAS 2025/A/11209 - page 3

the Training Period, while, during the same period, the Player apparently played a sig6. Pursuant to the information presented to the Sole Arbitrator during these proceedings, the Player played a limited number of matches (around 10) for the Respondent duringCAS 2025/A/11209 - page 3

the Training Period, while, during the same period, the Player apparently played a significant number of matches (at least between 40 and 50) for a number of other football clubs in different UK leagues, including the clubs Lordswood, Walton and Hersham, Staines Town, Grand Athletic and Corinthian Casuals.

7. By email of 17 May 2022, because interested in signing the Player, the Appellant wrote, inter alia, as follows to the Player’s representative, Mr Simon Ledwith: “[…] I have obtained Wasiri’s player passport from the FA which is attached. Currently, if Wasiri signed for Swansea City on a professional contract the club could be liable to pay a large sum of training compensation to his previous clubs.

Unfortunately we are not currently in a position to proceed. We would require waiver letters from all clubs from age 12 to current stating that no training compensation is playable [SIC] in relation to the player. The attached player passport only lists his clubs from age 19 but as stated, we would need letters from all of his clubs from age 12 upwards if possible. […]”

8. On the same date, the Chairman of the Respondent wrote, inter alia, as follows to the

Appellant: “[…] Regarding player Wasiri Ola Williams; he was registered with Hatcham FC on a non contract/playing basis only I can confirm we will not seek compensation for the time he has spent with us.

[…]”

9. Based on the above, the Appellant answered as follows: “Many thanks for your e-mail and confirmation.

Please could you put this onto club letterhead (if possible), sign the document and scan to me?”

10. On 19 May 2025, the Respondent forwarded to the Appellant a scanned document (the

“Many thanks for your e-mail and confirmation. Please could you put this onto club letterhead (if possible), sign the document and scan to me?”

10. On 19 May 2025, the Respondent forwarded to the Appellant a scanned document (the “Waiver”) bearing the letterhead of the Respondent and signed by the Chairman of Hatchham FC, Mr Ryan Reynolds. The waiver had the following wording: “Regarding player Wasiri Ola Williams; he was registered with Hatcham FC on a non contract/playing basis only I can confirm we will not seek compensation for the time he has spent with us.”CAS 2025/A/11209 - page 4

11. On 16 June 2022, the Player transferred on a permanent basis from Braintree Town FC to the Appellant and was registered for the first time as a professional.

12. The Appellant is a UEFA Category I club.

13. The transfer of the Player to the Appellant on 16 June 2022 triggered in principle the right to training compensation for the clubs that have contributed to the Player’s training and development in accordance with the applicable FIFA rules.

B. Proceedings before the FIFA Dispute Resolution Chamber

14. In July 2024, the Respondent lodged a claim before the FIFA DRC on the basis that the Appellant had failed to pay training compensation to the Respondent in the amount of EUR 172,356.16 plus 5% interest p.a. as of the due date until the date of effective payment.

15. In support of this claim, the Respondent submitted, inter alia, that it was entitled to training compensation for the 700 days the Player was registered with the Respondent as an amateur due to its past involvement in the training and education of the Player in accordance with Article 20 of the FIFA Regulations on the Status and Transfer of Players (the “FIFA RSTP”) and Article 2 (1) of Annexe 4 of the FIFA RSTP.

16. On 14 August 2024, the FIFA administration issued a proposal to the Parties for the

accordance with Article 20 of the FIFA Regulations on the Status and Transfer of Players (the “FIFA RSTP”) and Article 2 (1) of Annexe 4 of the FIFA RSTP.

16. On 14 August 2024, the FIFA administration issued a proposal to the Parties for the payment of “EUR 172,168.20 as training compensation plus 5% interest per annum as from 17 July 2022, until the date of effective payment”. Such a proposal was tacitly accepted by the Respondent but rejected by the Appellant.

17. In its reply, the Appellant rejected the claim and submitted that the Chairman of the Respondent had signed a valid waiver which clearly and unequivocally renounced the Respondent’s right to training compensation.

18. In its rejoinder, the Respondent contested the validity of the waiver since it is not explicit nor specific to the training compensation entitlement foreseen in Article 20 and Annexe 4 of the FIFA RSTP.

19. The FIFA DRC initially established that the applicable law is the June 2022 edition of the FIFA RSTP and the March 2023 edition of the Rules Governing the Procedures of the Players’ Status Committee and the Dispute Resolution Chamber (the “Procedural

Rules”).

20. The FIFA DRC then acknowledged that the Appellant , on the one hand, rejected the Respondent’s entitlement to training compensation, inter alia alleging that the latter had waived its training compensation entitlement. The Respondent, on the other hand, contested the validity of the waiver since it is not explicit nor specific to the training compensation entitlement.

21. Based on the above, the FIFA DRC then took into account the jurisprudence of the FIFA DRC pursuant to which the validity of a conventional waiver is subject to a clear andCAS 2025/A/11209 - page 5

unequivocal declaration by the party concerned, requiring clear language reflecting the party’s clear intention to renounce its right.

22. The FIFA DRC further noted that implied waivers are not recognised. Accordingly, and

unequivocal declaration by the party concerned, requiring clear language reflecting the party’s clear intention to renounce its right.

22. The FIFA DRC further noted that implied waivers are not recognised. Accordingly, and given that training compensation is a right stipulated in the FIFA RSTP, the existence of a waiver of this right may only be assumed in case it was unmistakable that the r enouncing club has indeed intended to waive its right to training compensation.

23. In other words, the FIFA DRC found that the said jurisprudence requires a document; a) containing a clear and unequivocal ren unciation of training compensation, and b) issued by the party concerned by such renunciation.

24. In light of the above, the FIFA DRC then held that the alleged waiver did not contain a clear and unequivocal renunciation of training compensation, and as such, the first prerequisite of a valid waiver is not met.

25. Consequently, the FIFA DRC decided that the Respondent’s entitlement to training compensation for the first professional registration of the Player with the Appellant had not been waived.

26. The FIFA DRC then turned its attention to the calculation of the training compensation, emphasising that training compensation is calculated based on the number of years of training and education provided by the previous training clubs multiplied by the training costs of the new club, cf. Article 5 (2) of Annexe 4 of the FIFA RSTP.

27. According to the Player Passport issued by the FA, the Player was registered with the

Respondent as an amateur for 700 days as follows: a. From 7 November 2019 until 31 December 2019, i.e. for 55 days of the year of the player’s 19th birthday; b. From 1 January 2020 until 31 December 2020, i.e. for 366 days of the year of the player’s 20th birthday; and c. From 1 January 2021 until 6 October 2021, i.e. for 279 days of the year of the player’s 21st birthday.

player’s 20th birthday; and c. From 1 January 2021 until 6 October 2021, i.e. for 279 days of the year of the player’s 21st birthday.

28. The FIFA DRC then recalled that the Appellant was a UEFA Category I club, with training costs of EUR 90,000 per year, at the time it registered the Player as a professional.

29. In light of the above, the FIFA DRC found that the Respondent is entitled to receive training compensation in the amount of EUR 172,168.20 as follows: “a. EUR 13,561.64 for the 55 days of training at the calendar year of the player’s 19th birthday;

b. EUR 90,000 for the full year of training at the calendar year of the player’s 20th birthday; andCAS 2025/A/11209 - page 6

c. EUR 68,606.56 for the 279 days of training at the calendar year of the player’s 21st birthday.”

30. Moreover, the FIFA DRC decided that the Respondent is entitled to receive 5% interest per annum and until the date of effective payment, i.e. as from the date on which training compensation became overdue: 17 July 2022.

31. Based on the above, on 8 January 2025, the FIFA DRC rendered the Appealed Decision and decided that: “1. The Claim of [Hatcham] is partially accepted. 2. [Swansea] has to pay to the [Hatcham], EUR 172,168.20, as training compensation plus 5% interest p.a. as from 17 July 2022, until the date of effective payment.

3. Any further claims of [Hatcham] are rejected.

4. Full payment (including all applicable interest) shall be made to the bank account indicated in the enclosed Bank Account Registration Form.

5. Pursuant to article 24 of the Regulations on the Status and Transfer of Players if full

3. Any further claims of [Hatcham] are rejected.

4. Full payment (including all applicable interest) shall be made to the bank account indicated in the enclosed Bank Account Registration Form.

5. Pursuant to article 24 of the Regulations on the Status and Transfer of Players if full payment (including all applicable interest) is not paid within 45 days of notification of this decision, the following consequences shall apply: 1. [Swansea] shall be banned from registering any new players, either nationally or internationally, up until the due amount is paid. The maximum duration of the ban shall be of three entire and consecutive registration periods.

2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee in the event that full payment (including all applicable interest) is still not paid by the end of the three entire and consecutive registration periods.

6. The consequences shall only be enforced at the request of [Hatcham]in accordance with article 24 paragraphs 7 and 8 and article 25 of the Regulations on the Status and Transfer of players.

7. The final costs of the proceedings in the amount of USD 16,000.00 are to be paid by

[Swansea] to FIFA reference to case no. TMS 14403 […]”

32. On 4 February 2025, the grounds of the Appealed Decision were notified to the Parties.

III. PROCEEDINGS BEFORE THE COURT OF ARBITRATION FOR SPORT

33. On 25 February 2025, the Appellant filed its Statement of Appeal in accordance with Articles R47 and R48 of the Code of Sports -related Arbitration (the “CAS Code”) against the Respondent and FIFA.CAS 2025/A/11209 - page 7

34. By letter of 26 February 2025, FIFA noted, inter alia, that “the Appealed Decision is not one of disciplinary nature ”, and that “ the appeal in question does not appear to contain any substantial request against FIFA ”, based on which FIFA submitted that it “lacks any legal interest in the matter (not to say standing to be sued) ” and therefore

not one of disciplinary nature ”, and that “ the appeal in question does not appear to contain any substantial request against FIFA ”, based on which FIFA submitted that it “lacks any legal interest in the matter (not to say standing to be sued) ” and therefore asked to be excluded from the present proceedings.

35. By letter of 3 March 2025, the Appellant informed the CAS Court Office that it accepted FIFA’s request to be excluded from the proceedings, and by letter of 4 March 2025 from the CAS Court Office, it was confirmed that FIFA was excluded from the proceedings.

36. On 7 March 2025, the Appellant filed its Appeal Brief in accordance with Article R51 of the CAS Code.

37. On 28 April 2025, the Respondent filed its Answer in accordance with Article R55 of

the CAS Code.

38. By letter of 29 April 2025, in accordance with Article R54 of the CAS Code, the Parties were informed that Mr Lars Hilliger, Attorney-at-Law in Copenhagen, Denmark, had been appointed as Sole Arbitrator.

39. By letter of 6 May 2025 to the CAS Court Office, the Appellant wrote, inter alia, as follows: “[…] In light of the lack of any witness evidence produced by the Respondent, and in order to assist the Panel’s better understanding of the extensive evidence adduced by the Appellant in this case, under the provisions of Article R44.3 of the Code (applicable mutatis mutandis to the appeal proceedings under Article R57 of the Code), the Appellant requests that the Respondent provides voluntarily: (1) witness evidence from the Respondent itself in respect of (at the very minimum): a. the communications which took place with the Player’s representative, Simon Ledwith, in respect of the Player joining the Respondent and the waiver requested from it; b. the process of signing the waiver letter at the Appellant’s request (see page 310 of the Appendix to the Appeal) and what the Respondent meant at the time when the waiver

with, in respect of the Player joining the Respondent and the waiver requested from it; b. the process of signing the waiver letter at the Appellant’s request (see page 310 of the Appendix to the Appeal) and what the Respondent meant at the time when the waiver was signed on 19 May 2022 by stating: (i ) the Player was being registered for the Respondent on a “playing basis only”; and (ii) it not seeking “compensation for the time he has spent with us”. In other words, what was the Respondent agreeing to waive by way of “compensation” when the Player was at that time an amateur player; c. its knowledge of the dual registrations system at an amateur level in England and the regulations that a player can be registered for more than one team at the same time (see the standard league rules at 18(H) at page 464 of the Appendix to the Appeal); d. its knowledge of the Player playing for other clubs over the same period of time which he was registered to play for it; e. the Player’s playing history for it; andCAS 2025/A/11209 - page 8

f. evidence of the Player’s actual registration dates with it in light of the submissions from the Kent County Football Association that the Player was not registered for it for the 700 days claimed (see page 439 of the Appendix to the Appeal). Holding this information is required of the Respondent under the standard league rules at 18(J) (see page 464 of the Appendix to the Appeal) with rule 18(k) confirming that registrations are for one Playing Season only. Note that Playing Season is defined as the period between the date on which the first competitive fixture in the Competi tion is played each year until the date on which the last competitive fixture in the Competition is played (see page 453 of the Appendix to the Appeal); (2) witness evidence from the Player in respect of (at a very minimum): a. whether the player: (i) who was registered for the clubs listed in the Appendix to the

the date on which the last competitive fixture in the Competition is played (see page 453 of the Appendix to the Appeal); (2) witness evidence from the Player in respect of (at a very minimum): a. whether the player: (i) who was registered for the clubs listed in the Appendix to the Appeal which are not shown on the player passport; and (ii) who has the same name, date of birth and likeness as him, was him or not; b. his playing history with the Respondent and his evidence on page 486 of the Appendix to the Appeal that he never trained with the Respondent; c. whether the X (formerly Twitter) account with the handle @wwasirii belongs to him, as an account with that handle: (i) shows images of a player which resembles him; and (ii) details his involvement at clubs not listed on the player passport e.g. with Corinthian Casuals (see page 593 of the Appendix to the Appeal); and d. whether the YouTube clip of a player with the same name and likeness of him having signed to play for Grand Athletic in December 2020 is actually him or not (see page 584 of the Appendix to the Appeal); and (3) documentation within its possession, custody and control relating to the Player’s registration for it and the Player’s time actually spent with the Respondent, including its correspondence with the Player, his agent/representative (and/or former agents/representatives) and its correspondence with The Football Association, its County Football Association and affiliated leagues, including but not limited to: a. the full chain of correspondence between the Respondent and The Football Association. This has not been disclosed by the Respondent’s representatives, merely the response from The Football Association to its request. This is key to understanding the response of The Football Association in the light of what was requested; and b. any correspondence with the Player’s representative Simon Ledwith in or around May 2022 when the waiver document was requested to be sent to the Appellant. The email sent to Mr Ledwith (see page 302 of the Appendix to the Appeal) makes it quite

b. any correspondence with the Player’s representative Simon Ledwith in or around May 2022 when the waiver document was requested to be sent to the Appellant. The email sent to Mr Ledwith (see page 302 of the Appendix to the Appeal) makes it quite clear th at the waiver requested is in respect of training compensation and that the Player would not be signing for the Appellant without such documentation. This documentation is key to understanding the Respondent’s understanding and intention in May 2022 when agreeing to waive “compensation” for the time the Player was registered for it.CAS 2025/A/11209 - page 9

It is understood that the Player re-registered to play for the Respondent in both the SFL – London league and the Orpington and Bromley District Sunday League this season prior to his move overseas to play football in Latvia. It is therefore evident that t he Player has been in contact with the Respondent this season, so it is not understood why this evidence could not have been supplied with the Respondent’s Answer. In the event that the above evidence is not provided voluntarily by the Respondent, the Appellant requests that the Panel order the production of the requested information. [….]”

40. By letter of 14 May 2025, the Respondent requested that the Appellant’s request for submission of new evidence be rejected.

41. By letter of 20 May 2025, the Parties were informed that the Sole Arbitrator had decided to have a hearing in the present matter, which would be held by videoconference. Moreover, the Parties were informed that he had decided to deny the Appellant’s request for the production of evidence.

42. The Sole Arbitrator found no exceptional circumstances which he deemed would be applicable to the late request in accordance with Article R56 of the CAS Code, and the Sole Arbitrator further noted that in its Appeal Brief the Appellant had not called, or even mentioned, the possibility of calling any other witnesses other than Mr Greenwood.

applicable to the late request in accordance with Article R56 of the CAS Code, and the Sole Arbitrator further noted that in its Appeal Brief the Appellant had not called, or even mentioned, the possibility of calling any other witnesses other than Mr Greenwood.

43. By letter on 26. June 2025, the Appellant forwarded a request for admission of additional evidence under Article R58 of the CAS Code, since such evidence “was unfortunately received shortly after the Appellant’s Appeal brief was submitted to the CAS on 7 March 2025, however, the information contained was requested prior to the deadline.” and since such evidence “is of exceptional importance and relevance to the arguments already presented in the Appellant’s submissions […]”.

44. By letter of 8 July 2025, the Respondent submitted that pursuant to Article R56 of the CAS Code, the new material was inadmissible and should be rejected.

45. By letter 12 August 2025, the Parties were informed that the Sole Arbitrator had decided not to admit the Appellant’s submission and new document dated 26 June 2025 into the file, as the Sole Arbitrator found no exceptional circumstances in this regard in accordance with Article R56 of the CAS Code.

46. The Parties both duly signed and returned the Order of Procedure.

47. On 28 August 2025, a video hearing was held.

48. In addition to the Sole Arbitrator, Mr Giovanni Maria Fares, Counsel to the CAS, and

the following persons attended the hearing: For the Appellant: Ms Lis Coley, Legal CounselCAS 2025/A/11209 - page 10

Mr Finley Davis, Paralegal Mr Gerard Cassidy, Financial Controller – Observer Mr Ben Greenwood, Head of Football Operation, Witness

For the Respondent: Mr Thomás Prestes Bosak, Legal Counsel

Ms Michelle Acierno, Legal Counsel

49. At the outset of the hearing, the Parties confirmed that they had no objections to the appointment of the Sole Arbitrator or in any other regard.

For the Respondent: Mr Thomás Prestes Bosak, Legal Counsel

Ms Michelle Acierno, Legal Counsel

49. At the outset of the hearing, the Parties confirmed that they had no objections to the appointment of the Sole Arbitrator or in any other regard.

50. The Sole Arbitrator heard the evidence of Mr Greenwood, who was invited by the Sole Arbitrator to tell the truth subject to the sanctions of perjury under Swiss law. The Parties and the Sole Arbitrator had the opportunity to examine and cross -examine the witness.

51. The Parties were afforded ample opportunity to present their case, submit their arguments and answer the questions posed by the Sole Arbitrator. After the Parties’ final submissions, the Sole Arbitrator closed the hearing and reserved his final award.

52. Upon the closure of the hearing, the Parties expressly stated that they had no objections in respect of their right to be heard and to have been treated equally and fairly in these arbitration proceedings.

IV. SUBMISSIONS OF THE PARTIES

53. In its Appeal Brief, the Appellant requested the CAS to issue an award as follows: “(a) the appeal filed by the Appellant is upheld;

(b) first: (i) the Decision to award the Respondent training compensation be set aside and replaced with a new decision confirming the validity of the Respondent’s waiver submitted to FIFA TMS by the Appellant; and (ii) to reverse or amend the decision in respect of the payment of costs of those proceedings due to the incorrect submissions to the FIFA DRC made on behalf of the Respondent; (c) in the alternative, only if … is not accepted by the CAS: (i) the Decision to award the Respondent training compensation be set aside and replaced with a new decision which reflects the amended registration history of the Player significantly reducing the sum of training compensation payable to the Respondent; and (ii) to reverse the decision in respect of the payment of costs of those proceedings due to the incorrect

award the Respondent training compensation be set aside and replaced with a new decision which reflects the amended registration history of the Player significantly reducing the sum of training compensation payable to the Respondent; and (ii) to reverse the decision in respect of the payment of costs of those proceedings due to the incorrect submissions to the FIFA DRC made on behalf of the Respondent;CAS 2025/A/11209 - page 11

(d) in the alternative, only if both … and … are not accepted by the CAS: (i ) the Decision to award the Respondent training compensation be set aside and replaced with a new decision significantly reducing the level of training compensation adjudicated by the FIFA DRC, being grossly disproportionate to the time that the Player actually spent being trained and developed by the Respondent; and (ii) to reverse or amend the decision in respect of the payment of costs of those proceedings due to the incorrect submissions to the FIFA DRC made on behalf of the Respondent; (e) in any event: (i) the Respondent shall be required to pay to the Appellant the FIFA procedural costs in the sum of USD 16,000 incurred by it in requesting the grounds of the Decision; (ii) the Respondent shall be required to pay to the Appellant the CAS Court Office Fee and the advance of costs incurred by it in bringing this appeal before the CAS as well as any costs incurred by the CAS in excess of this sum; and (iii) in accordance with Article R64.5 of the CAS Code, the Respondent shall be required to pay to the Appellant a contribution towards its legal fees and other expenses incurred in connection with these proceedings.”

54. The Appellant’s submissions, in essence, may be summarised as follows: - Article R57 of the CAS Code gives the Sole Arbitrator the full power to review the facts and the law. The Sole Arbitrator may issue a new decision which replaces the decision challenged or annul the decision and refer the case back to the previous instance.

• Article R57 of the CAS Code gives the Sole Arbitrator the full power to review the facts and the law. The Sole Arbitrator may issue a new decision which replaces the decision challenged or annul the decision and refer the case back to the previous instance. - Moreover, pursuant to the applicable rules, the CAS has the power to admit evidence that was available at the time when the Appealed Decision was issued in the interests of ensuring the correct decision is reached. - Due to the circumstance of the case, including the request made by the Player in return of giving evidence in these proceedings, the CAS should not draw any adverse inference from the failure of the Appellant to obtain witness evidence from the Player.

The Waiver: - In June 20222, when the Player signed his first professional contract with the Appellant, the FIFA Clearing House was not yet in operation, and therefore the document issued was the traditional player passport rather than the Electronic Player Passport. - The Appellant had no reason at the time when the Player Passport was issued to doubt its accuracy and therefore it placed reliance on it. The issue of reliance on the Player Passport therefore only came to light around two years after the Player signed for the Appellant rather than during the Electronic Player Passport review phase. - The evidence on file confirms that professional players are not permitted in the Orpington and Bromley District Sunday Football League, apart from in very limitedCAS 2025/A/11209 - page 12

circumstances, which do not apply here. The Respondent, which participates in the said Sunday Football League, therefore was not permitted to register the Player under contract and benefit from the additional protections and compensation which this status affords a club. - Moreover, it is no