Bribery in sport is not an uncommon phenomenon. From boxer Eupolos bribing fellow Olympic Games competitors in 388 BC (Spivey, 2012), to bookmakers bribing stable-boys to dope horses in the 1960s (Reid, 2014), to FIFA Executive Committee members being bribed to secure their votes (Blake and Calvert, 2015; Conn, 2018), sport is awash with examples of this form of corruption.

Bribery and corruption in international sport are rife, systemic, widespread, and linked to stakeholders from athletes to sponsors, although the governance side of the game has gained most attention. For example, FIFA's 2015 governance corruption scandal led to most of their Executive Committee indicted in the US or sanctioned internally (Conn, 2018).

Bribery damages the integrity and image of sport (Gorse and Chadwick, 2010; Kihl et al., 2017) and undermines efficiency and growth within the industry (Azfar et al., 2001). Despite continuing vulnerability to this form of corruption, there is limited literature on how International Sports Governing Bodies (“ISGBs”) tackle bribery through the use of anti-bribery and corruption (“ABC”) corporate governance and ethics policies.

There are also no global, functional best practice guidelines available for implementation by sport organizations (Michie and Oughton, 2005), although some countries have created their own, linked to public funding availability (Australian Sports Commission, 2015, 2020; Sport England UK Sport, 2016). The UN (2017) has also issued guidance on ABC measures for countries tackling corruption in sport. ABC policies are required to ensure that ISGBs can be held to account, and clear policies allow for sanctions against breaches. Absence of adequate policies therefore affects propensity for corruption, although benchmarking of individual ISGB's ABC governance is outside the scope of this paper.

Challenges faced by the sport industry in designing and implementing ABC policies include different structures and hierarchies within ISGBs (Chappelet and Mrkonjic, 2013; Pielke, 2016; Gardiner et al., 2017), lack of awareness of governance problems leading to conflict of interest and fraud (Brooks et al., 2013; Kirkeby, 2016), and ability to indulge in regulatory arbitrage for country of incorporation (Geeraert et al., 2014; Pielke, 2016). For example, the 2015 FIFA scandal was linked to problems with structure of both ISGB and member federations (Tighe and Rowan, 2020), conflicts of interest (Blake and Calvert, 2015), and the protection that Swiss company law previously afforded ISGBs (Associated Press, 2014).

As ISGBs are the regulators of their sport, an evaluation of their ABC policies is required to understand the problem, and provide best policy recommendations to other ISGBs. This paper's research aim is an exploratory qualitative evaluation of ABC policies of ISGBs with regards to policy content and language. This is done against the anti-bribery framework developed by Philippou (2019) for assessing ABC policies based on interdisciplinary corruption research. The intention is to highlight best practice policies (and those missing) within this framework currently adopted by some ISGBs, and outline issues raised on the risk of bribery in ISGBs as a group.

This paper's contribution to knowledge is a critical review of the diverse current ISGB anti-corruption governance policies for the prevention of bribery.

The next section of this paper argues that corporate governance policies are applicable to ISGBs, then provides an overview of ABC literature, followed by a section that outlines the framework used and method employed in the assessment of ABC policies, and a discussion of the results by framework element.

The European Sports Charter states that “voluntary sports organizations have the right to establish autonomous decision-making processes within the law” (Council of Europe, 2001, Article 3.3). While autonomy has led to self-regulation (Forster and Pope, 2004; Forster, 2006; Chappelet, 2016), some researchers have argued that ISGBs are indeed corporations despite this status (Szymanski and Kuypers, 2000; Barker, 2013). Smith and Stewart (2010) noted that the unique features of the sport industry have diminished since the 1990s from ten (Stewart and Smith, 1999) to four, including having legally allowable monopolistic and/or oligopolistic structures, supporting corporate governance policy applicability to sports organizations.

Governance provides solutions to issues identified by agency theory (Jensen and Meckling, 1976) as applied to sport. Agency problems can be caused by separation (Berle and Means, 1930) between principals (resource allocators and stakeholders such as fans and athletes) and agents (managers of these resources, such as ISGBs).

ISGBs have developed into large revenue-takers and increased their visibility (PWC, 2011, 2016; Gardiner et al., 2017).

Corporate governance of ISGBs is thus increasingly important to governments and policy-makers. Political bodies such as the Council of Europe now regard sport governance as a key issue; they approved the 2013 Berlin Declaration calling for the sport industry's engagement with corporate governance issues (Geeraert, 2016; Gardiner et al., 2017) and adopted the Good Football Governance Resolution (Council of Europe, 2018).

Given the autonomy principle, with sport given special dispensation under law (Council of Europe, 2001), it should be unsurprising that ISGBs are different in their governance and board structure when compared to other corporate organizations, particularly with regards to lack of accountability,. This is especially so when those charged with governance are uninterested, unaware, and/or unable to recognize corruption (Brooks et al., 2013; Kirkeby, 2016).

Proposed solutions to corporate governance problems (and links to corruption) faced by ISGBs put forward by researchers and policy-makers include:

Researchers have attempted to develop benchmarking tools for assessing the strength of corporate governance structures in sport organizations (not necessarily ISGBs). However, if autonomy and self-regulation are indeed part of the reason for poor governance across the sporting industry, then comparisons with peer organizations would be of limited value as an ABC tool. The Action for Good Governance in International Sport's (“AGGIS”) benchmarking tool targeted the areas of transparency, and checks and balances. Both transparency and accountability linked to checks and balances are frequently used controls in the ABC sphere (Solomon, 2013, pp. 151–190) and are covered later in this paper.

Chappelet and Mrkonjic (2013) composed a set of indicators for measuring corruption in sports governing bodies, including organizational and reporting transparency, control mechanisms, and sport integrity, which overlap with the ABC framework (Philippou, 2019) used in this paper. Other benchmarking that has been applied to sport governance includes Play The Game's National Sports Governance Observer (Geeraert, 2018; Alm, 2019). There was, however, no explicit coverage of anti-bribery measures within the benchmarking assessments, and this is a suggested area for further research.

Limited research exists on ABC elements within sport governance. One example includes Pielke (2016), who assessed the conflict of interest and other ABC measures at FIFA against a framework of accountability mechanisms (including legal, market, peer, and public reputational accountability), but not stakeholder accountability. Over the same period, FIFA did well in the AGGIS benchmarking, coming second in the list of 35 Olympic sports federations (Geeraert, 2015).

The methods noted above have been rarely adopted with an emphasis on ABC, although attempts to increase transparency across a number of organizations has taken place over time, and there is limited research into ABC corporate governance applications for ISGBs. This paper aims to begin the process of addressing this paucity of knowledge by analyzing best practice as a first step toward an ABC best practice code in line with Michie and Oughton (2005) and Pielke (2016).

Like corruption (Ashforth and Anand, 2003; Den Nieuwenboer and Kaptein, 2008; Gorse and Chadwick, 2010; Rose, 2017), bribery encompasses an array of definitional issues and is affected by public sector literature bias. This may be in part due to the sense in which sport is a public good even if the bodies running it are not.

ISGBs are, usually, privately incorporated associations, in which corruption is often internal to organizations (vote-rigging, fraud, match-fixing), although senior executives have held public office alongside their ISGB roles. One notable exception is the hosting, by countries, of major sporting events such as the Olympics and the FIFA World Cup. For these events, government-provided infrastructure and entertaining of ISGB members by public officials is often required, and external bribes and procurement fraud may occur (Dorsey, 2015).

Bribery can be defined as the “offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust” (Transparency International, 2017b). This definition is broader than public-sector definitions (such as that of the Foreign Corrupt Practices Act (Sarbanes-Oxley, 2002) in the US), despite raising perspective issues through not defining the terms “ethics” and “breach of trust,” and is therefore the one used in this paper.

There are limited empirical studies on bribery. Hanousek and Kochanova (2016) found “local bribery environments” affected firm performance in European countries, although the focus was on public-sector officials. Rodrigues-Neto (2014) modeled different forms of bribery to show that where monetary bribes are paid, bargaining power of bribe-payers is relatively small. Other works focus on detection or bribery within the framework of corruption (see, for example, Ryvkin et al., 2017) or on problems associated with bribery from a business perspective (Bray, 2007; Transparency International, 2011). These latter studies are based on perception, measuring beliefs rather than quantity (Sampford, 2006; Brooks et al., 2013). This paper analyses ABC policies rather than quality or quantity of bribery incidences, although perception does play a part in reputational damage suffered by companies as a result of corruption.

There is a limited range of theoretical frameworks available for critical evaluation of ABC policies. One such example is De Waegeneer et al. (2016), who created a classification framework for content analysis of ISGBs' ethical codes' effectiveness. This included thematic and procedural classifications of content, both of which are relevant to general governance policies, but not explicitly concerned with ISGBs. Another is the TASP sport corruption typology of Masters (2015), which can be applied explicitly to instances of corruption in sport or framing specific scandals within ISGBs.

Svensson (2005) describes corruption as an outcome ‘of a country's legal, economic, cultural and political institutions'. Bribery, in turn, is an outcome of a number of similar variables, both thematic and procedural, which need to be addressed in an ABC policy.

Philippou (2019) sets out a theoretical framework for bribery in sport governance. The framework (Figure 1) is split into three parts: clarifying concepts (such as definitions of corruption and bribery employed), assessing risk factors (economic rent, discretionary powers, and culture), and assessing governance (accountability, monitoring/control systems, and enforcement). As this framework is explicitly concerned with ABC in sport governance, and its production based on an amalgamation of interdisciplinary ABC research, this is the framework used in this paper. Its elements and the relevant literature are discussed below.

The global scope and activities of ISGBs makes them subject to varied ABC legislation and regulations, which internal policies and codes need to comply with. The ISGBs' ability to take advantage of regulatory arbitrage (such as the ICC's move from the UK to Dubai in 2005) affects the policies and procedures required and therefore enacted.

The US FCPA's (1977, §78dd-3) definition of bribery requires involvement of a public official (UK Government, 2010). The UK Bribery Act 2010 has a much broader definition of bribery, covering private sector bribery (and therefore ISGB officials), passive as well as active bribery (both giving and receiving a bribe), and facilitating payments. Facilitating payments are inducements given to officials to perform routine business transactions in their (legal) job. Facilitating payments are allowable under the FCPA (Baughn et al., 2010), although enforcement has tightened up in recent years.

ISGBs could potentially be affected by public-sector facilitating payment definitions during sport event management and related procurement activities, or during broadcast rights negotiations. ISGBs could also be affected by private-sector bribery in, for example, requesting support in the form of votes in exchange for allocating funds to specific development programs.

Given the reputational risk from being embroiled in a bribery scandal (Gorse and Chadwick, 2010), ISGBs should also include unactioned (agreed but not acted upon) bribery in their definitions. This is because mere agreement to conduct bribery could still damage the ISGB's reputation, as is the case with the unproven allegations of match-fixing in tennis (Mitchell, 2016; see, for example, Blake, 2016). By extension, when these practices become endemic to the culture, it's woven into the fabric of the sport, as was the case with the cultural problems experienced by the Australian cricket team (Lemon, 2018).

The anti-bribery framework developed by Philippou (2019) was used to critically evaluate the publically available ABC policies and procedures of 22 ISGBs (listed in Table 1). Assessing the ABC methods employed requires substantive disclosure evidence from the ISGBs on their internal organizational structures and policies employed. This is not always available, and differs from ISGB to ISGB.

In line with the concept of economic rent influencing corruption (Klitgaard, 1988), the sample of ISGBs used in this research were the largest. This conforms with findings by Maennig (2005), where only sports able to generate high income (and economic rents) were affected by corruption, although these findings may have been affected by selection bias in classifying “major documented cases” (p. 190). This approach is also consistent with the sample selection by Geeraert et al. (2014), and Gorse and Chadwick (2011) in their analyses of governance issues and corruption in sport respectively.

Arriving at a sample of the ISGBs with the largest revenues was hindered by some ISGBs not publishing their financial statements (covered in the transparency and accountability section below). Therefore, the list of profitability by sport is an incomplete one. The researchers proxied size to popularity, as defined by their visibility in the media and on terrestrial broadcasting in the largest sports markets (Chadwick, 2013, p. 515; Geeraert et al., 2014, 2015; PWC, 2016). Table 1 lists the sports sampled and their associated ISGBs. Note that the IOC was included (and referred to as an ISGB) in this paper because compliance with the IOC's regulations are the explicitly stated basis for many other ISGBs' policies.

All available documents on structure, governance, financial controls, integrity, and anti-corruption were downloaded from the sample ISGB websites in May 2017 and December 2020 and content analysis performed thereon. The analysis was performed on two dates to also assess ISGB progress with regards ABC policies.

Of the 22 ISGBs reviewed, one (IRB, 2017, 2020) had no relevant documents available on their website (during either timeframe).

The diversity of information available, and the relevant conclusions drawn from this, is discussed in the section on transparency and accountability.

Thematic analysis was undertaken on the ISGB documents available following the approach set out by Braun and Clarke (2006, 2016), followed by the thematic [based on the Philippou (2019) ABC framework] evaluation of the qualitative results (Stemler, 2001; Robson and Mccartan, 2016; p. 349). These 95 (in 2017) and additional 82 (in 2020) documents were reviewed and analyzed by the researchers, using NVivo qualitative data analysis software. The first stage of coding involved reviewing the policies within the documents. Themes were generated from an initial coding run to identify any themes related to anti-bribery and corruption. A second stage of coding was then conducted on the content identified, amalgamating any related codes (such as cash and monetary payments) and splitting any codes that required it (such as ABC). The codes were then compared to the framework and a final analysis was performed on the data to ensure both the themes arising from the data and framework concepts were covered in the analysis. The process was then repeated in 2020 with the additional/updated documents downloaded in December 2020.

Of the 22 ISGBs reviewed, 14 had an ABC policy of some description in place in 2017, while a third had none publicly available. In 2020, this was increased to 17 so that the absence of ABC policies was less common across the group. Eight ISGBs in 2017 and nine in 2020 had specific ABC policies, while others had included them within other documentation such as a Code of Conduct, Code of Ethics, or Constitution. This has implications for all elements of the assessing governance section of the anti-bribery framework, as lack of easy-to-find, clear-cut policies might limit the strength of the internal control system. It also supports the argument for increased need for staff training on the topic.

Another issue was the inconsistency within ISGBs' policies. An example of poor practice in the 2017 batch was the ITF's (a private registered UK company subject to the UK Bribery Act 2010) policy, which noted that “payment of facilitation payments by or on the behalf of the ITF is therefore only permitted if the following conditions are met …” (ITF, 2012). This implied that facilitation payments are acceptable under certain circumstances, although it then contradicts this in the same document by (correctly, for a company registered in the UK) defining facilitation payments as an example of non-permissible bribery (ITF, 2012). In the 2020 sample for coding, the Anti-Bribery and Corruption Code of Conduct had been replaced by two anti-corruption program documents (ITF, 2020a,b), neither of which specifically referenced bribery. Bribery was instead referenced in the general anti-bribery and corruption clause in the ITF Code of Ethics (ITF, 2019).

References coded to bribery and corruption themes included:

Who was subject to the policies differed across ISGBs sampled. All applied to officials (see, for example, IFAF, 2012; IIHF, 2014a; World Rugby, 2017; Wbsc, n.d.) and/or athletes and their representatives (IIHF, 2014a; WBC, 2015b). Some had a very broad stakeholder scope, including “the cities and countries wishing to organize” competitions' (FIBA, 2014a), or ‘Representatives of sponsors, partners, suppliers, ski industry and media dealing with FIS and/or have an involvement in FIS activities' (FIS, 2016b). These present best practice solutions for corporate governance issues as put forward by Michie and Oughton (2005) and Pielke (2016). Some ISGBs specifically referred to stakeholders as a “family” (FIFA, 2012a; IAAF, 2015), re-enforcing the idea of self-governing autonomy (Forster and Pope, 2004; Forster, 2006), but also potentially contrary to the independence ideals embedded in a culture of accountability and transparency (Geeraert, 2016; Maennig, 2016).

The ITF and FIA were the only two from the 2017 sample of ISGBs that defined the term bribery as “the offering, promising, giving, accepting or soliciting of an advantage (whether financial or otherwise) as an inducement for an action which is illegal or a breach of trust” (ITF, 2012), or the more specific “improperly influenc[ing] anyone, or … reward[ing] anyone for the performance of any function or activity, in order to secure or gain any commercial, contractual, regulatory or personal advantage” (FIA, 2017b). In the 2020 sample, FIFA defined bribery as an “offer of anything valuable with the intent to gain an improper business advantage” (FIFA, 2020e) and the IRL as “an inducement or reward offered or promised in order to gain any commercial or other advantage” (IRL, 2020a). These are in line with the general definitions discussed previously (2002; Transparency International, 2017b). The FIA further illustrate best practice by providing examples, including “the giving of aid or donations, the use of voting rights, designed to exert improper influence” (FIA, 2017b).

Where references existed to bribery, the second round of coding for each batch determined if non-financial bribery was included (which is definitional-dependent). Non-financial bribery is defined in this paper as the exchange of something other than money in the course of the bribe, such as votes, personal or political favors, or role allocation within an organization. Non-financial bribery was defined in one of three ways in the sample, with some ISGBs incorporating more than one definition:

Non-financial bribery aligns with the “breach of trust” element of the Transparency International (2017b) definition of bribery, and aligns with corruption seen in the 2015 FIFA scandal, where favors were allegedly swapped for votes (Conn, 2018).

The importance of reputational risk to ISGBs was noted, including references to “illegal, immoral and unethical behavior” (FIFA, 2012b), “foster[ing] public confidence in … governance and administration” (ICC, 2014a), “refrain[ing] from unethical behavior that may bring disgrace to many people involved in the sport” (WBC, 2015a), and “not act[ing] in a manner likely to tarnish the reputation of the Olympic Movement” (IOC, 2020a). IFAF summaries this as “Public confidence in the authenticity and integrity of the sporting contest and in the uncertainty of its outcome is vital. If that confidence is undermined, the very essence of the sport is compromised” (IFAF, 2017a). These results support the narrative that integrity of sport is important to ISGBs.

It follows that ISGBs should therefore value ABC, given bribery's damaging nature to integrity (Gorse and Chadwick, 2010). In line with this, unactioned bribery should be covered in best practice ABC policies, and it was indeed covered by some ISGBs. For example, reference was made to breaches occurring “irrespective of whether such benefit is in fact given or received” (IGF, 2016a). However, it could be argued that unactioned bribery is covered by the term “bringing the sport into disrepute” (see, for example, IFAF, 2017b). The issue, from an enforcement perspective, is the breadth of the latter term may make it harder for investigators to prove compared to breaches of specifically referenced bribery, and thus best practice should include specifics.

There was evident progress in the amount and quality of ABC material provided by ISGBs between the two sample periods (see Table 3), FIFA and the ITF in particular. Aside from illustrating some ISGBs' growing commitment to transparency and accountability, this also supports Ionescu (2015) research on the role of the media in increasing accountability, as these changes were likely brought in as a result of media scrutiny (Ingle, 2017).

This paper critically reviewed governance policies for the prevention of bribery in a sample of 22 ISGBs using the anti-bribery framework developed by Philippou (2019). The diversity of both the quantity and quality of information on corporate governance and/or ABC policies is part of the problem that needs to be addressed by future guidance. It is difficult for members and stakeholders to know where to look for ABC information, as this is distributed among statutes, codes of ethics, codes of conduct, or other documents. Future quantitative research can be undertaken to assess policy frequency and distribution.

Qualitative examples of both good and poor practice currently followed by some ISGBs were highlighted across both periods and are summarized in Table 4. There was no single area of the framework that ISGBs performed well at as a collective, and there was no single ISGB whose ABC policies were strong across all areas. A recommended subject for further research is whether particular characteristics of ISGBs positively affect particular aspects of their governance and ABC procedures.

There are limitations of using publically available information for this study, as the information may be incomplete. However, this also reflects the lack of transparency and accountability of the ISGBs in question, and arguably contributes to the likelihood of bribery by those charged with governance (Klitgaard, 1988) of sport.

In terms of clarifying concepts (Philippou, 2019), clear ABC policies on their websites, defining bribery, or including unactioned bribery (which would affect reputation), were few, and there were a number of inconsistencies within ISGBs' own policies. Thus, ISGBs should focus on clarity and consistency when strengthening their ABC policies, starting with defining what it is that they expect their members and stakeholders to avoid.

Governance structures found supported the applicability of corporate governance ABC policies to ISGBs, in line with Smith and Stewart (2010) paper on the sport industry's declining uniqueness. Governance aims of the sample ISGBs converged with regards the importance of integrity, supporting research on risks arising from a lack of integrity (Gorse and Chadwick, 2010). This shows the importance of industry reform in line with other industries, as opposed to an introverted outlook often adopted by sport organizations.

Accountability was deemed important by ISGBs in their documents, but no single ISGB included full information on roles, conflicts, personnel responsible, and so on, while one ISGB had no documents available at all. This paucity in transparency was in line with findings by Geeraert et al. (2014) and is another focus for IGBS looking to undertake reform of their governance and ABC policies and procedures.

Clear gifts and entertainment policies existed, but only one specified a maximum acceptable level of spend. Given the number of reputation-afflicting scandals linked to gifts and entertainment, and the cultural shift away from these as a method of doing business, focus on these policies would enhance the current ABC provisions in ISGBs.

The majority of monitoring and control (Philippou, 2019) references related to whistleblowing. These were, on the whole, scarce, with some ISGBs making reference to reporting hotlines, which can help identify breaches (ACFE, 2016), and a minority to protection of whistleblowers, which help more come forward (Soon and Manning, 2017).

Enforcement powers were low, thus limiting their effectiveness (Croall, 2004), without committees having the power to sanction, while a lack of independence in ISGBs sampled increases discretionary powers of governing officials and therefore the likelihood of bribery (Klitgaard, 1988).

There are, of course, limitations to generalizing the results of this study to all ISGBs. Each ISGB, as shown in this paper, caters to different stakeholders, has different aims, with different governance structures, and very diverse revenue streams and levels. However, this study also highlights why best practice needs to be tailored to the sport industry as a whole, and why ISGBs should share and act on good practice (such as the examples provided by Interpol (2020) on their bi-weekly bulletins, or ESSA (2017).

Most importantly in terms of the practical application of this research for best practice, the existence of robust ABC policies and procedures still requires adherence to and enforcement of these principles. For example, FIFA came under criticism in 2017 for not renewing the independent Ethics Committee's terms, thereby damaging ongoing internal investigations into corruption (Conn, 2017a,b).

The need therefore remains for sharing best practice, and providing guidance on, ABC policies for ISGBs, via the IOC or external enforcement organizations such as UNODC (2018) or stakeholder pressure groups such as SIGA (2017). Future research should engage with stakeholders and ABC practitioners to create a practical and realistic blueprint for best practice in the sport industry and beyond (Michie and Oughton, 2005; Pedersen, 2016; Pielke, 2016). This could be done through interviews or focus groups with ABC professionals, sport governance officers, legal personnel, and stakeholders to analyze perceptions of corruption and ABC in ISGBs against the Philippou (2019) and/or the Masters (2015) frameworks. This can be complimented with research ranking ISGBs by expanding Geeraert's (2018) system to include ABC, and to benchmark the ISGBs sampled.

There is a need to fill the research gaps that exist in relation to both the incidence of bribery, and the fight to prevent it, including research around policy issues and requirements for robust ABC policies, in order to allow for “sport played and governed under the highest integrity standards, free from any form of unethical, illicit and criminal activity” (Siga, 2017).

CP compiled the dataset and conducted the analysis of the data. CP was the senior author of the paper. TH is the second author. All authors contributed to the article and approved the submitted version.

The authors declare that the research was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.