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Alexandra Wrage
President and Founder, TRACE

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Nicola Bonucci 
International Lawyer and former
Director for Legal Affairs OECD
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
Writer's pictureNicola Bonucci

Ethics and Major Sporting Events

Paris Olympics

Now that my mandate, initiated six years ago, as a member of the Ethics Committee of the Paris 2024 Organising Committee (“the Committee”), is coming to an end, it is time to share some views about a unique and incredible experience.

 

The Articles of Association of the Organizing Committee for the Olympic and Paralympic Games (“Paris 2024”), adopted on December 21, 2017, provided in Article 29 for the creation of an independent Ethics Committee, responsible for developing and supervising the ethical policy of Paris 2024 as managing conflicts of interest.

 

The Ethics Committee was set up and elected its Chairman on July 13, 2018. I was lucky enough to be one of the six members acting pro bono.

 

Since then, the Committee met for more than 50 formal sessions. In addition, there have been preparatory meetings, and meetings to finalize opinions and recommendations.

 

The Committee has adopted a broad conception of its mission, as shown by the range of subjects covered in its annual activity reports, all publicly available. It also monitors the effective application of its recommendations and opinions. It is not an investigative body and assumes no managerial responsibilities.

 

So, what are the institutional and substantive lessons to be drawn?

 

Institutionally, it is clear to me that any world sporting event such as the Olympic Games, the World Cup, and others, should set up an independent Ethics Committee but that such committee should present very specific features:

 

First, this Committee should be given the dual role to set up the policies and monitor their implementation, this therefore requires that it be set up well in advance.

 

Second, such a Committee should be independent, broad in terms of its mandate (including the possibility to “self refer” issues), transparent in terms of policy and general advice, effective in terms of individual and tailor made advice, respected, and respectable.

 

Third, the size of the Committee should be manageable but should also ensure a diversity of profiles and views.

 

Fourth, for the Committee to be effective some continuity in its membership is essential.

 

Substantively what have I learned?

 

On substance, challenge number one is conflict of interest:  be it real, apparent, or potential.  In a small community like the sport community, you cannot and shall not avoid any type of conflict of interest, but you should manage and mitigate any conflict to the fullest possible extent. We have provided both general policy and dealt with specific situations with this in mind.

 

Challenge number two is the incredible complexity linked to the organization of a major sporting event, particularly the Olympic Games.  A number of issues, like the participation of athletes from Russia and Belarus, were not in Paris 2024 hands, but still questions were raised.

 

Challenge number three is the incredible level of scrutiny around these events. Geopolitical considerations and ESG concerns may have an impact in terms of ethical risks. As an Ethic Committee we could not ignore them but within the limits discussed below.

 

Challenge number four is to maintain the limits of the Ethics Committee role. As indicated above, the Ethics Committee is not an investigative body and assumes no managerial responsibilities. Some discussions were borderline but we collectively managed to remain in our remit.

 

Challenge number five is how to balance the need for resources in terms of sponsorship and other forms of financial and technical assistance with the need to have open and transparent procedures for issues such allocations of tickets, handling of the torch, location of events, etc…

 

For those who want to know more, several informational materials, including the code of ethics, are available in English, though, much to my regret, more is available in the French version (https://olympics.com/en/paris-2024/committee/our-responsibilities/ethics-committee).

 

As we are now talking about the Paris 2024 legacy the experience of the Ethics Committee should be part of it and I hope L.A 2028 may take some inspiration.



International Lawyer, Former Director for Legal Affairs, OECD

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