Confidential Reporting Policy
World Rugby is committed to ensuring that the game of Rugby is carried on at all times with complete integrity and in compliance with relevant laws and regulations and in accordance with the highest standards of ethics.
To enable World Rugby to further its efforts to preserve the fundamental character of sporting competition as an honest test of skill and ability and to prevent corrupt gambling practices from undermining the integrity of the Game, World Rugby has developed its own Anti-Corruption Regulations. Pursuant to World Rugby’s Anti-Corruption Regulations, World Rugby has established a protocol to facilitate the submission to World Rugby of confidential reports (the “Confidential Reporting Protocol”) to provide an opportunity for “Connected Persons” and others to notify World Rugby of potential violations of its Anti-Corruption Regulations.
The purpose of this Policy is to:
- outline the legal basis on which we operate the Confidential Reporting Protocol;
- outline how you can disclose information to us under our Confidential Reporting Protocol;
- outline the protection that may be available if you do avail of under our Confidential Reporting Protocol; and
- describe how we handle reports received under our Confidential Reporting Protocol.
In addition to this Confidential Reporting Policy, personal information gathered by us pursuant to our Confidential Reporting Protocol is subject to our Privacy Statement. For more information please see our Privacy Statement.
1. On what legal basis does World Rugby operate the Confidential Reporting Protocol?
World Rugby administers this Confidential Reporting Protocol on the legal basis of its legitimate interests, as the world governing body of Rugby Union, in preserving preserve the fundamental character of Rugby Union as an honest test of skill and ability and to prevent corrupt gambling practices from undermining the integrity of the Game. In identifying these legitimate interests, World Rugby has taken into account the fundamental rights of individuals who may be identified pursuant to this Confidential Reporting Protocol and has determined that manner in which this Confidential Reporting Protocol furthers its legitimate interests in safeguarding the integrity of the Game is proportionate to those rights.
Where we collect and process information which may be shared law enforcement authorities, regulatory or other appropriate bodies in connection with any investigation or which may relate to the commission of any criminal offence, our legal basis for doing so is that it may be necessary for complying with applicable law or with a request from a competent authority.
2. How does the Confidential Reporting Protocol work?
Our Confidential Reporting Protocol enables Connected Persons(as defined below), and other people, to submit reports, on a confidential basis, (“Confidential Reports”) to World Rugby of potential violations of its Anti-Corruption Regulations.
Confidential Reports may be submitted via the following means:
- In person to a World Rugby Anti-Corruption Officer;
- By emailing our confidential mailbox: [email protected] (the “Confidential Mailbox”); or
- By using the online reporting form provided at http://integrity.worldrugby.org/index.php?report=form&language=en (the “Online Reporting Form”).
3. Who is affected by this Confidential Reporting Policy?
All Connected Persons (as defined in World Rugby’s Anti-Corruption Regulations) are expected to make reports of any approach, invitation, offer, solicitation, inducement, enticement, instruction, persuasion, encouragement, payment or facilitation to them or any other Connected Person which may relate to these Anti-Corruption Regulations and any other conduct, information or credible suspicion about any conduct which may breach or be relevant in relation to the Anti-Corruption Regulations or which may pose a threat to the integrity of the Game.
A Connected Person is, effectively, anyone involved in the Game in any way at the international, professional, semi-professional and any other levels of the Game where players are paid. For further guidance as to whether you are a Connected Person, please see here: http://integrity.worldrugby.org/index.php?module=1§ion=1.
Individuals who are not a Connected Person are also encouraged to report any actual, potential or suspected breach of World Rugby’s Anti-Corruption Regulations.
4. When should Confidential Reports be submitted?
If you are a Connected Person, you are expected to report any approach, invitation, offer, solicitation, inducement, enticement, instruction, persuasion, encouragement, payment or facilitation to them or any other Connected Person which may relate to World Rugby’s Anti-Corruption Regulations and any other conduct, information or credible suspicion about any conduct which may breach or be relevant in relation to the Anti-Corruption Regulations or which may pose a threat to the integrity of the Game.
If you have made any Attempt to breach the Anti-Corruption Regulations, you are encouraged renounce this Attempt by making a report to World Rugby and/or World Rugby’s Anti-Corruption Officer of the circumstances of such Attempt.
Even if you are not a Connected Person, you are encouraged to report any actual, potential or suspected breach of World Rugby’s Anti-Corruption Regulations. By doing so, you help to protect the image and integrity of the game of Rugby and help us to identify, investigate and seek to eliminate, activities which may be in breach of our Anti-Corruption Regulations.
5. Why should I report an approach or suspicion of breach?
Breaches of World Rugby’s Anti-Corruption Regulations which have the potential to damage the image and integrity of the game of Rugby. Your report can help to identify, expose and investigate activities which are in breach of World Rugby’s Anti-Corruption Regulations and can thereby help to protect and enhance the image of the game of Rugby, as well as furthering World Rugby’s core values of Integrity, Discipline, Respect and Solidarity.
While you may also speak to your local Union or Players' Association regarding an approach or suspicious activity, reporting to World Rugby as the central body is an obligation on all Connected Persons and is essential to ensure that all relevant information which may relate to corrupt approaches or corruption in the Game is filed in one place. This allows World Rugby and Unions to monitor reports, behaviours and potential breaches from one centralised database. For example, a corrupter or gambling syndicate may operate across various countries and World Rugby needs to know about their activities globally to be able to protect participants in the Game wherever they are.
Your report can help to identify and expose activities which are in breach of World Rugby’s Anti-Corruption Regulations or which have the potential to damage the image and integrity of the game of Rugby.
Any contact you make with World Rugby will be treated with the utmost confidence.
In most countries, as well as contacting World Rugby, you may also be obliged to report match-fixing or potential corruption in sport to your local police service. Your Union or Players' Association may be able to advise you further in this regard.
Remember, World Rugby, your Union and/or Players' Association will help you before it's too late.
6. How can reports be submitted?
Confidential Reports can be submitted either:
- In person to a World Rugby Anti-Corruption Officer;
- By email to our Confidential Mailbox; or
- By using the Online Reporting Form.
7. What happens when I submit a Confidential Report via the Confidential Reporting Protocol?
Receipt of your report will be acknowledged in writing and a time period specified for a response. Normally this will be within 14 days although certain enquiries may take longer subject to the circumstances involved.
We will review the content of your Confidential Report in detail, taking care to ensure the confidentiality and security of the report. Following such review, we will take one of the following steps:
- We may determine that no further steps are required to be taken on foot of your report. In this case, we will not action your report any further and your report will be deleted within 6 weeks of its receipt;
- We may determine that the content of your report is such as to justify opening an investigation (whether on its own or when read in conjunction with other information or evidence available to us) into any matters identified in your report or to be used in connection with an investigation which has already been opened (combination with other info);
- We may determine that further information or clarification is required before we can identify appropriate next steps. In this case, we may need contact you to clarify or expand on the information you have provided. We look forward to your continued assistance if this is necessary.
Where we proceed under step 3 outlined above, we will re-assess any further information or clarification you provide, in conjunction with your original report, and following such further review, will assess which of the three steps should then be taken.
Where we proceed under step 2 outlined above, we may share information with World Rugby’s Member Unions (who may have responsibility for conducting investigations), law enforcement authorities, regulatory or other appropriate bodies in connection with any investigation. In certain circumstances, we may be under a legal requirement to disclose information contained in a Confidential Report to competent law enforcement authorities.
8. How are Confidential Reports protected?
All Confidential Reports will be dealt with on a confidential basis (irrespective of whether you submit your report anonymously or are asked to include your name, your information) and your identity will not be disclosed without your agreement. World Rugby treats Confidential Reports with the greatest of care and confidence. It is expected that you will observe the same standards of confidentiality whilst your matter is being dealt with.
Our Confidential Mailbox and Online Reporting Tool are administered and maintained by our Integrity Office and access to reports submitted via these mechanisms is limited to members of our Integrity Office.
Your Confidential Report will only be disclosed to third parties in the circumstances described above (see “What happens when I submit a Confidential Report via the Confidential Reporting Protocol?”).
9. How is personal information used?
The personal information we collect pursuant to our Confidential Reporting Protocol includes any information you provide about yourself (where you choose to identify yourself in your Confidential Report) and any information you provide about any other individuals identified in the content of your Confidential Report.
In order to maintain the confidentiality of your report and to avoid any prejudice to any investigation into breaches of World Rugby’s Anti-Corruption Regulations or into breaches of applicable law or regulation, we do not inform other individuals you may identify that we have obtained their personal information in a Confidential Report. However, “Connected Persons” are made aware, through training and education programmes, of their obligations and expectations under World Rugby’s Anti-Corruption Regulations and of the possibility that information relating to them may be collected in connection with reports of, or investigations into, actual or suspected breaches of the Anti-Corruption Regulations.
Your identity will not be disclosed to any third party unless it is necessary to do so in the context of further investigation or legal proceedings (including procedures under World Rugby Regulation 18), or in circumstances where it is necessary for the purposes of the investigation, is required by law, is in the public interest, is necessary to prevent commission of crime, or where you consent to such disclosure.
Personal information of individuals identified in a Confidential Report may be used in the investigation of breaches of World Rugby’s Anti-Corruption Regulations and/or into breaches of applicable law or regulation. In the event that disciplinary procedures are invoked in respect of an alleged breach of World Rugby’s Anti-Corruption Regulations, individuals who are the subject of such procedures will be informed of the evidence collected about them in accordance with World Rugby Regulation 18.
Where your Confidential Report is used in any investigation, personal information contained in such report may be combined with other personal information collected from other sources in respect of the same individual. Personal information may also be shared with World Rugby’s Member Unions (who may have responsibility for conducting investigations), law enforcement authorities, regulatory or other appropriate bodies in connection with any investigation. In certain circumstances, we may be under a legal requirement to disclose information contained in a Confidential Report to competent law enforcement authorities.
In addition to this Confidential Reporting Policy, the personal information you provide to us via our Confidential Reporting Protocol is subject to our Privacy Statement. For more information please see our Privacy Statement.
10. May I submit a report anonymously?
Persons submitting information have the right to do so anonymously should they so wish. If you wish to submit a report anonymously, you may do so by emailing our Confidential Mailbox or by using our Online Reporting Form. If you intend to submit an anonymous report via the online reporting form, please ensure you do not include your name on the form. If you intend to submit an anonymous report by emailing our confidential mailbox, please ensure that your email is sent from an email account which is not capable of identifying you.
To further enhance your security and anonymity, please follow these instructions:
- In the event that you would like to remain anonymous, do not submit any information that can be traced back to you.
- Make sure that the internet connection is secure which is displayed by the lock symbol in your browser.
- Note that an intranet connection, in particular, may jeopardize your anonymity.
11. Abuse of Confidential Reporting Protocol
In using our Confidential Reporting Protocol, you agree that you shall not impersonate any person or entity and/or adopt names and/or addresses (including without limitation email addresses) for the purpose of cyber squatting and/or falsely state or otherwise misrepresent any purported fact, matter or information including without limitation your affiliation and/or connection with a person or entity or otherwise make any statement which you know or reasonably believe not to be true and correct in any Confidential Report. You verify that information contained in a Confidential Report is true and correct to the best of your knowledge and reasonable belief. In addition to being a material violation of the terms on which the and potentially a breach of applicable laws and regulations in certain jurisdictions, a breach of the foregoing may amount to Misconduct under the World Rugby Regulations and World Rugby may take such action as it considers appropriate in such circumstances.