response to the fa's inclusion & anti-discrimination action plan

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A Point by Point Response to The Football Association’s English Football’s Inclusion and Anti-‐Discrimination Action Plan

INTRODUCTION

Detailed below is a point by point response to the FA’s “92 Point Plan”. This report has been compiled by:

The Society of Black Lawyers Nirvana FC The Association of Black Coaches

THE FA: LEADERSHIP

1 Establishing an Inclusion Advisory Board, reporting to The FA Board, to provide guidance on all equality matters and to verify and monitor the delivery of the action plan.

• Satisfactory: Who will be on this board? Will they truly be independent? Will the FA support and listen to them? Will it have any real power? Does this support or replace the FA Board Advisory Group for Race Equality? Why?

• It is important that the Board has a clear democratic process and a commissioning perspective so as to ensure that is truly representative and has sanctioning powers on any inter-‐agency or FA Policy that relation to all statutory aspects of discrimination from Policy Development, Recruitment, Selections, Action Planning and allocation of Budget.

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2 Commissioning an independent audit of equality education provision and its effectiveness in the game.

• Satisfactory: What education provision? The FA offer a free online equality and diversity course which covers disability, race, faith and gender which is questionable in its content and there is no requirement to complete it. They also offer a range of workshops which appear to be rarely, if ever, delivered. In addition how do you truly measure the effectiveness of these?

• It is important that the board use an Equality impact analysis of previous educational provisions throughout it inter-‐related divisions; National Game and Professional game, and set up Equality competences for all it staff linked to realistic targets linked into appraisal of all staff. It is important that the education links to sports science, sports psychology, Sports Ethic and Sports Management with a critical link to current Equality legislation. It is important Equality Education be integrated as a measurable performance of all licensed tutors and be part of their CPD clearly linked into Safeguarding, Medical Science, Psychology, and Coach Education, from Youth Award to Pro-‐License Level 5.

3 Developing and implementing an equality monitoring tool for use by all of the football organisations and their members, to provide a current and accurate picture of the diversity of the football workforce. This equality monitoring will include data on staff, Boards, and membership.

• Good: Most of this data should be easily available from databases already held by the FA e.g. Licensed Coaches, Licensed Tutors, Charter Standard Club Development plans, Referees Association etc. The depth of this data is also important i.e. what level of the game, geographical area etc. to provide a clear picture.

• Strategically this should be first priority of the Organisation that informs its Policy, Procedures and Equality Action Planning. The data should be measured again previous Equality Plans over a twenty year period, its now important to have an Equality performance officer independent of the FA to feedback on 6 monthly basis the areas mentioned above, but more critically in terms of recruitment and selection, allocation of funding to Equality areas. The data should be linked into the Equality monitoring framework and should be available to the public audience in which the forum could circulate during its road show for consultation. This would enable us to support the FA’s ability to increase participation rates, develop more confidence in existing and new procedures and to develop a grass-‐roots Rooney model.

4 Coordinating the collation of statistics in relation to relevant incidents and cases in football, and where appropriate working in partnership with the UK Policing Football Unit in relation to the evaluation of recorded incidents in the game.

• Satisfactory: This may not paint an accurate picture of the problem. Many of the incidents are not reported for fear of recrimination or that nothing will be done about it.

• The recent five live radio show suggested the FA received 185 complaints, it is important now as discussed at the BACA Black History Month Forum with Clarke Carlisle that the FA, Kick it, FARE, Respect, County FA’s, have one inter-‐related reporting system and a clear procedure process of reporting, complaints and responses that considers the statutory

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importance of the Football Offence Act, Criminal Justice Act and the 2000 Amendment Act. More crucially there is a real need for a community specialist panel to work with the Football Agencies and the Police.

THE FA: EDUCATION

5 Implementing learning and development and refresher programmes for its staff and County FA staff.

• Satisfactory: This seems very tokenistic. • This could be important to crossed-‐reference to point 2, in that CPD should include an

Equality competence assessment linked to data analysis and the achievement of targets in the four crucial areas of County FA staff work; Representation (Board), Workforce Development, Retention, Raising the Game, Better Standards. We are presently working with 8 counties in these areas.

6 Implementing mandatory learning and development programmes for coaches and referees taking FA qualifications.

• Good: Every coach and referee should undertake some sort of training. Even if it doesn’t change people’s attitudes directly it shows that the FA takes the issues seriously. My concern is that this would be a token effort i.e. the online course they currently have which covers a range of areas (see point 2). Delivering a blanket equality and diversity course devalues each of the issues involved. In addition who would deliver this training?

• It more important that the training is clearly informed by an Equality Model and Ideology that we can affect and change with reference to clearer definitions of institutional discrimination (See Macpherson (1999), Bradbury (2010). It is crucial that we (Gladwell, Blink approach) shape the cultural lenses of the training by writing and contributing towards Welfare, Safeguarding, Four Corners, Elite Player Performance models by up dated and culturally relevant scientific, psychological and political models of anti-‐discriminatory training.

7 Delivering refresher training to the 1200, FA Learning Licensed Tutor workforce.

• Satisfactory: As with the all the above points in this section a 3 hour workshop is unlikely to change people’s attitudes. In all instances ensuring there is equal representation would have a far stronger effect. We would suggest that the number of BAME tutors is not representative of the number of candidates from these groups, this is certainly true within Leicester.

• As a Licenced Tutor Coach Educator Level 1 and Level 2, Safeguarding, First Aid and Equality Tutor, it important as mentioned above in point 6 that we try and affect the content and the trans-‐cultural delivery of the course. It is important that we ensure that the training impacts on delivery, action planning and mentoring. It is important that that the FA examine the core cultural measurable competences and an impact analysis in terms of increasing new BME tutors (2017 target) in relation to the audit in areas of significant levels of under-‐

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representation. It is important that ‘whiteness’ as an equality training aspect be developed, and the training be linked to appraisals.

THE FA: CULTURAL CHANGE

8 Reviewing and promoting existing codes of conduct and social media guidance including the Respect Codes of Conduct within the Women’s Super League, semi-‐professional game and grassroots.

• Poor: There must be congruence with the professional game. A Women’s Super League player was found guilty of commenting on the sexuality of a referee on twitter. She received a 6 game ban (over 40% of a 14 game season). That is totally disproportional to sanctions handed out in the male professional game.

• The Codes of Practice needs to be linked to measure cultural competencies particularly in relation to the coaching, scouting and existing strategies that connect the FA future game strategy with Elite Player performance strategy.

9 Calling on UEFA to consider minimum standard codes of conduct within UEFA Licensing.

• Satisfactory: Again we appear to be discussing “codes of conduct” rather than concrete policies and only asking them to “consider” their introduction.

• This an extremely important piece of work in terms of the strategic link between UEFA and the FA, and we may need to act as a consultancy broker between FARE and Kick it out, in which both organisation are not representative in the workforce of BME personnel.

10 Working with the County FAs to review their inclusion and anti-‐discrimination programmes and interventions in grassroots leagues and clubs.

• Satisfactory: What inclusions and anti-‐discrimination programmes? I don’t think I’ve seen any within Leicestershire. Will there be additional funding available to support these programmes?

• This is an extremely important piece of work especially again in terms of us putting together an National Race Equality Plan (absent from the FA duties that focus on gender and disability strategies 2008-‐2012) so we can shape changes in the Counties priorities particularly in terms of Work force development and Representation on boards, this is part of our BACA 45 project.

11 Promoting the ‘Crowd Management Measures’ – Good Practice guide to professional and semi-‐professional Clubs.

• Poor: A good practice guide? There need to be clear and specific policies enforced. These need to be consistent with the Public Order Act 1986, take account of the definition of racially aggravated offences (the Crime and Disorder Act 1998), and the MacPherson Enquiry report

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12 Achieving the Advanced level of the Sport England Equality Standards and in partnership with the County FAs reviewing the Equality Standards for County FAs, requiring that all County FAs achieve the Foundation level by 2015 and the 10 counties with the most diverse local demographics, should achieve the Preliminary level of the standard by 2015. The County FAs will also be expected and encouraged to adopt local Race or Equality Advisory Groups, to guide and advise them on community engagement in all aspects of county football.

• Inadequate: For County FA’s to only meet the Foundation level by 2015 is not adequate nor is it for counties with more diverse populations to achieve the Preliminary standard. By stating that the FA as a whole will achieve the advanced standard (they are already at the Intermediate level) allows for them to swerve the issue as it is only at this level that requirements for leadership and staff to reflect the community they serve. For example they would only need to employ 20% of non-‐white British staff nationally to meet the standards however the community within Leicester City is 55% non-‐white British. In turn how stringently is this reviewed and monitored by Sport England?

• It is crucial that the BACA, which we have trying to do in the last twenty years, develop a National Race Equality plan, linked to the data analysis that informs the statutory duties of the FA Board and FA Counties that is linked to current censor data of 2011, which may have to involve Sporting Equals who are supported by Sport England.

13 Reviewing and where appropriate adapting and promoting FA programmes such as Tesco Skills, Mars Just Play and Vauxhall Mash Up to Black, Asian and Minority Ethnic and faith-‐based male and females.

• Inadequate: Why would the programmes need adapting for BAME players? I would question if there is a problem with the number of BAME players participating in football. The issues are around them having the same opportunity to excel as white players. Please see quote below from the UK Sport survey into sports participation and ethnicity in England:

Participation in football amongst males from ethnic minority groups is relatively high. This is particularly the case amongst Black males with participation rates as high as 31% amongst the ‘Black Other’ ethnic group, which is three times the national average (10%). Given the publicity about the lack of representation of Asian footballers at the highest levels it is interesting to see that participation amongst these groups is around the national average and exceeds it in the case of Pakistani men (16%)

• With this in mind consideration needs to be made to why BAME players not engaging with these programmes? Are programmes accessible for BAME players and are the people who organise and run them sensitive to these issues and representative of the communities they serve? Considering the statistic outlined in the previous point all the FA Skills coaches in Leicester are white British?!

• It is important that we influence, the science and psychological models and develop a set of trans-‐cultural delivery competencies that changes the culture and improve the statistical representation particular in areas of under-‐representation in relation to the transition from the grass-‐roots to the Professional game in conjunction with Asian into Football Forum.

14 Ensuring that where complaints or charges of discrimination relate to Charter Standard Clubs these are reviewed (as part of the annual health check) to demonstrate they are

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acting in accordance with their equality policies and practices and taking action where this is not the case.

• Poor: If a club is charged with racial discrimination they should face far more severe sanctions than being simply reviewed (particularly by a process which is done annually anyway)! In addition who conducts these reviews? Are they independent or at least verified by an independent body (REAG or the Society of Black Lawyers in the case of racial issues)? In addition what action will be taken if found not to be acting in accordance to equality policies (which you would expect if they are found guilty of discrimination)? There needs to be clear sanctions in line with the seriousness of the offence. Charter Standard is the FA’s benchmark for quality for grassroots clubs and can influence funding applications etc. We would argue this is already a flawed system (How many BAME clubs are Chartered Standard Community Clubs?) however to allow a club who are found guilty of racial discrimination to keep this accolade without serious actions being taken is totally unacceptable.

• We need to ensure that the process is trans-‐parent and the health check should be part of the registration process in terms of the cultural competences of the charter clubs to ensure that it’s safeguarding, welfare; coaching; inclusion policies; and practices that are anti-‐discriminatory.

15 Continuing to engage faith-‐based communities through its ‘Faith in Football’ education programme at Wembley and to promoting this concept to professional Clubs and County FAs, as a model for community engagement.

• Poor: Clubs such as Leicester Nirvana have players from a number of different faiths playing football together on a weekly basis, not just on 4 days over the course of 12 months like this initiative

THE FA: REGULATION AND REPORTING

16 Ensuring the transparency of its regulatory process and providing clarity and guidance on how to report concerns and allegations about discrimination in football.

• Good: The transparency of the process is vital. This could increase confidence in reporting incidents however again we would like to see more specifics on how they intend to achieve this and by when.

• Sporting Equals and range of grassroots and professional organisations need set up a panel to devise a one system approach from grassroots to the professional game from telephone, on-‐line, and a range of social media reporting. The audit of this information should be used to review the types of individual and institutional changes needed, very similarly to the case review process that operates in relation to Child Protection.

17 Exploring a more effective mechanism for hearing cases of aggravated misconduct and discrimination and raising confidence in the reporting and disciplinary process at grassroots level.

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• Satisfactory: All they appear to be committing to is “exploring” a more effective way of hearing cases? How do they plan on doing this? Are they actually going to change anything based on their explorations? We believe that raising confidence in the process is vital but this will only be brought about by clear and specific policies and procedures. Yet again how do they plan on measuring their success on this point? The FA failed to prevent or discipline the conduct of Liverpool FC and Chelsea FC who intervened in the disciplinary cases of both John Terry and Luis Suarez as exposed by Lord Ouseley in December of last year. In direct contrast to their failure to prevent this interference they then disciplined the victim Rio Ferdinand for one tweet comment about Ashley Cole. The FA have little or no credibility of protecting the integrity of the victim on their past form so need to address this in a far more radical manner.

• There is a major problem that BACA has identified is the lack of confidence in the CRB system and the potential exclusion of BME coaches who have records that does not fit into the tolerance level of the FA CRB panel.

18 Reviewing its Guide to Misconduct Report Writing for referees, to ensure that referees understand the definitions in The FA’s Regulations, which reflect the Equality Act, 2012 and their obligations in relation to reporting discrimination, identifying clear examples of Law 12 being breached as a result of discrimination.

• Satisfactory: The Equality Act 2010 (EQA 2010) is the correct legislation! Will reviewing the guide necessarily ensure they understand the definitions and their obligations? Surely, more training needs to be provided for referees in this area. What is the consequence for a referee failing to report an incident? The reporting training of referees and standards have to be to the MacPherson definition for both racist and anti-‐Semitic incidents. Nothing less than that is acceptable.

• As a qualified referee and in light of the recent incident in Italy there needs to have clearer guidelines about the additional powers to support players who are being racially abused, and the power to use the information to refer to the criminal justice system.

19 Reviewing the sanctions regime to ensure that it is timely, appropriate, proportionate and effective at all levels.

• Very good: Needs to be done immediately and clearly communicated.

20 In addition to the implementation of appropriate FA Regulation working with the Premier League and Football League to sanction clubs who repeatedly fail to sanction their employees, who breach their contract or code of conduct, or deal inadequately with fans in relation to discriminatory language or behaviour.

• Good: Why repeatedly? Is using discriminatory language or behaviour included in all staff contracts? The FA only provide codes of conduct for Women’s Super League, semi-‐professional game and grassroots (see point 8). Will the Premier League and Football League also adopt this? What is deemed as inadequate for dealing with fans?

• What is the sanction of employing players, managers and coaches who we know have extremely right wing beliefs (Swindon and Leicester are two recent examples). At what point do we use the Criminal Justice system and the 1998 Legislation?

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THE FA: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

21 Continuing to promote open and transparent processes in advertising for and recruiting the football workforce including support for mentoring in relation to work placements in football, such as Kick It Out’s mentoring programmes.

• Inadequate: Is this even an action point? Surely it just says we’ll keep doing what we’re doing? According to point 3 they need an equality monitoring tool to provide a picture of the diversity of the football workforce therefore how do they know that these processes are effective?

• Many mentoring projects lack a detailed strategic analysis of the institution and a trans-‐cultural institutional approach that enables the culture of the organisation to adjust to the developmental needs of under-‐representative groups.

22 Utilising the County FAs local Race and / or Equality Advisory Groups, to capacity build the diversity of the football workforce e.g. to develop more women, ethnic minorities, LGB&T and disabled people. This will include implementing the recommendations from the recent review of Local Race and / or Equality Advisory Groups ensuring greater representation on Council and Committees, recruitment from a diverse talent pool, input to County Plans.

• Satisfactory: There seems to be clear issues with County FA’s utilising the REAGs (another box ticking exercise?). The football workforce is too general a term. What specific roles are these groups not applying for/being appointed to and why? Shouldn’t the recommendations from the advisory groups form specific points for this action plan? Actions such as ensure greater representation are too vague. There must be clearly enforceable targets with clear timelines and a person responsible for ensuring delivery of this action.

• Similar to the work of BACA there is a need for a National Inter-‐agency Race Equality plan cross-‐referenced to gender and disability and the recent Open door homophobia FA plan. It is really important that we write, influence and develop the plan as a central strategic driver to all equality work within the Counties particularly in relation to their 5 strategic objectives.

23 Reviewing alongside the Football League a recruitment processes for Managers and Coaches and developing a voluntary code, based on a set of principles for recruitment, which the Professional game may consider adopting for all roles in football.

• Inadequate: Are the Premier League not included in this? If this is a voluntary code then clubs will pick and choose when they apply it. This falls far short of the “Rooney Rule” and fails to commit the FA to “positive action”. The phrase “positive action” does not even appear anywhere in FA plan despite being a lawful response to combat racial discrimination that has been around since the 1976 Race Relations Act and is still lawful under the EQA 2010.

• The central role is pushing the contradictions between networks as a form of recruitment and clear objectified recruitment processes that are transparent and accountable to specialist equality panel that takes into consideration Pro-‐Licence qualification.

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24 Continuing to support and implement COACH and other programmes to capacity build coaches from Black, Asian, and Minority Ethnic communities, with higher level qualifications and experience to challenge for roles in the Professional game.

• Satisfactory: This appears to be a good scheme however as it is still relatively new it is not clear how effective it will be. This again isn’t really an action point as it is a scheme already in existence.

• The Coach programme lacks a clear coherent educational and mentoring programme from Level 1 to Level 4, an unclear and incoherent link between the Future Game, Youth Programme and working at Academies through the new requirements of the Elite Player Performance. There is a crucial need to link the COACH provision to the National Licensing work being carried by BACA in conjunction with Kick it out to develop a trans-‐cultural personal and institutional model to enable Professional clubs to work and progress the workforce development needs of BME coaches.

25 Ensuring that the number of coaches from Black, Asian, and Minority Ethnic communities, who are accessing the Level 1 and 2 coaching qualifications, remains reflective of national demographics and does not fall below 10% of the total number of coaches qualified at these levels.

• Satisfactory: The wording is confusing. Is it the number of people accessing the courses or those qualified at that level they are measuring? This is also interesting as the following statistics were presented to parliament in February 2012, therefore suggesting the most up to date data available; “The following statistics are for participants taking The FA’s coaching Qualifications in 2010:

Level 1: 8.5% of 27,380 coaches were from black, Asian and minority ethnic groups



• Why have they only set a target for level 1 and 2 coaches as there appears to be more issues with the higher level qualifications? Why was the data for level 4 and 5 not presented? It is also worth considering that all players on YTS contracts complete level 1 and 2 as part of their education programme. Also needs to be updated to 2011 census data.

• The data and process of collating information needs to be improved; we need to get Lisa from FA Licensing to find out the potential loss BME coaches applying for the License process, particularly in terms of the CRB requirement. The budget for transition to Level 3 and Level 4 needs to be seriously addressed, and we need more updated figures on BME coaches attending the Youth Awards 1-‐3. The BACA strategy clearly outlines it plans to improve the trans-‐cultural quality of delivery, assessment and mentoring, and to ensure that there are more equitable pathways to Coach Education, paid employment at Academies and the FA moves away from a needs lead approach to a quality based competitive approach.

26 Setting targets for the number of female coaches and the number of disabled coaches as part of The FA’s new Coaching Strategy.

• Poor: What are these targets?

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• BACA through a range of national and local events stressed the need for the FA 2008-‐2012 strategy under Pillar 3 to consult with BME coaches, to provide accurate data from the Counties and through the Regional Development managers, similar to the case in relation to the Disability and Women’s sport strategy. We also stressed the need to cross-‐reference race, disability and gender.

27 Setting targets to increase the ethnic diversity of FA Learning Licensed Tutors as well as targets for both the number of female and disabled coaches and Licensed Tutors.

• Poor: Too vague. • Martin Shaw King Trust in 2005, ran the first ever BME Level 4 Prep Course, and in 2006 ran

the first event BME Tutor training course, and in conjunction with FA ran the first ever Level 1 BME Tutor training course, in which only 25% were signed off as tutors, who were mainly signed off by myself. The central problem is the failure of FA 6 point plan in terms of FA License Tutor alienates BME tutors who are not being supported and sponsored by a County. At present, and it a major strategic issues, BACA is trying to ensure that each County in review of their four year plan write into their Workforce development plan opportunities for BME tutors to tutor in relation to Level 1, Level 2, Youth Award, First Aid and Safeguarding. We need a similar strategy in terms of the Regional Developmental Managers at Level 3 and Level 4.

28 Seeking to ensure that 10% of the national referee workforce is from Black, Asian, and Minority Ethnic communities, which is reflective of national demographics.

• Poor: Although it is nice to see a specific target as over 30% of players come from BAME groups we would argue that this is too low. By when do they plan to achieve this, the current figure is 3.2%. We would suggest there is a lot of work to do here. How do they plan to achieve this? Why is this the only workforce with a specific target? Again the population demography is not the appropriate benchmark but the % of BAME players so must be set at least 20% of all referees across the national workforce. The timeline should be within three years and left an undefined date at some point. The FA failure to address targets and timelines coherently makes you wonder if they are serious about dealing with the problem.

THE FA: SPECIFIC INTERVENTION – ASIAN FOOTBALLERS

29 Implementing programmes to increase the number of Asian boys and girls playing football

• Inadequate: Asian boys and girls playing football does not appear to be the problem (see response to point 13). More investigation needs to be made into why Asian players are not progressing to the elite level. In 2005 a report supported by Kick it out which Leicester Nirvana made numerous contributions to 'Asians can Play Football' was launched at Highbury the second such report. In this report there were numerous recommendations which over the last 7 year period have not been delivered on. The FA has a specific member of staff who headed up the “Asians in football” initiative for the FA which again have failed across the board on numerous delivery initiatives

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30 Alongside the County FAs implementing talent development programmes specifically in relation to Asian men and boys, via Development Centres and creating links to their local Asian community football clubs.

• Poor: I think the key focus here needs to be to develop the links with clubs with high numbers of Asian players rather than having specific development centres. The FA need to support the clubs in coach and facility development in order to create sustainable programmes to develop talented Asian players. Professional clubs also need to be involved in identifying and developing talented players.

31 Promoting Asian male and female role models in the game and seeking to diversify the pool of recruitment officers responsible for talent identification, from the Asian community.

• Poor: The action is around promoting role models however fails to identify the lack of them within a number of roles therefore not addressing the key issue. Within the male game recruitment officers (scouts) come from professional clubs rather than the FA therefore we do not see the relevance of this. The problem is not the absence of Asian talent but the inability of the majority of white scouts, and managers to recognise this talent in any meaningful way.

• We need to return to two excellent research papers, ‘Asians can’t play football’ and ‘Ten wasted years’ for us to address and redress the cultural scientific and psychological stereotypes inherent in the player performance, scouting and recruitment, especially in the context of the new EPPP. BACA in conjunction with the Asians into Football Forum, Butch Fatzal, have been working to together from 2010 to develop an trans-‐cultural model of coaching, scouting and player development from grassroots to the Professional game, in which we can monitor and assist the competencies of this work force area.

THE FA: SPECIFIC INTERVENTION – INTERNATIONAL FOOTBALL

32 Continuing its collaboration and forward planning on potential cultural and discrimination challenges when different countries are hosting international matches or tournaments under the jurisdiction of UEFA and FIFA.

• Poor: Again this is not an action point. The brave demonstration by Kevin Prince-‐ Boateng, the support by his team mates, black and white and the actions of the AC Milan management and the majority of supporters is likely to be more effective than the last 20 years of FA dialogue with UEFA and FIFA on race. The FA failed dismally to challenge the appalling threat of Michel Platini, the UEFA President at the European Championship who threatened that black players would be disciplined if they walked off when faced with racial abuse.

• This is a potential crucial area in the post-‐colonial area of the FA in terms of moving from a welfare model of developing communities to an empowerment model of self-‐development. As an ex-‐member of FARE 2009-‐2012, the major challenge is identifying, responding and have clear global policies in dealing with racial abuse, and my special area the trafficking/slavery/exploitation of African children in Europe and in the inner-‐cities of

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England particularly in the cultural failure of Boseman and the UN Convention 31 to change the economic relationship between European managers and African players.

THE COUNTY FOOTBALL ASSOCIATIONS: EDUCATION

33 Working with The FA to provide learning and development and refresher programmes in inclusion for staff and relevant volunteers.

• Repeat of point 5 above • We have a very important strategic role to examine and monitor the impact of the training,

the content of the training and to ensure that an Equality analysis is carried out.

THE COUNTY FOOTBALL ASSOCIATIONS: CULTURAL CHANGE

34 In conjunction with The FA, reviewing the Equality Standards for County FAs, with a target that all County FAs achieve the Foundation level by 2015 and the 10 counties with the most diverse local demographics should achieve the Preliminary level of the standard by 2015.

• Repeat of point 12 above • I am simply concerned about the positioning and responsibility of the other counties, and

their responsibility to examine issues of whiteness.

35 An expectation that County FAs will establish or maintain a local Race or Equality Advisory Group by 2015, including implementing the recommendations from the independent review. This will assist with guiding and advising CFAs on community engagement in all aspects of county football, including capacity building the diversity of the football workforce e.g. to develop opportunities for more women, ethnic minorities, LGB&T and disabled people and ensuring greater representation on Council and Committees.

• Poor: Why will this take until 2015? Leicester have had one for the past 2 years which has failed to make any impact due to lack of support from the county FA. The term “Greater” representation is far too vague. There is no hint of any sanction from the FA if County FA’s fail to act or are ineffective.

• Having participated in three Advisory Groups, London, Surrey and Middlesex, it is crucial as mentioned that we write and develop a National and Local Race Equality plan in which we can affect the Policy of the Counties.

36 Implementing inclusion and anti-‐discrimination programmes and promoting FA programmes (which may be adapted as appropriate) such as Tesco Skills, Mars Just

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Play and Vauxhall Mash Up to Black, Asian and Minority Ethnic and faith-‐based male and females.

• Repeat of point 13 above • The major issue here is the facility investment and funding to BME organisations in areas like

Brixton to ensure the programmes are equitable and have a strong trans-‐cultural ethos.

37 Ensuring that where complaints or charges of discrimination relate to Charter Standard Clubs these are reviewed (as part of the annual health check) to demonstrate they are acting in accordance with their equality policies and practices and take action where this is not the case.

• Repeat of point 14 above

THE COUNTY FOOTBALL ASSOCIATIONS: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

38 Using the Equality Monitoring Tool to provide data on Boards, staff and membership, to assist with the delivery of this target in the National Game Strategy.

• Poor: What target? We can see strategies to develop females and players with disabilities within the National game strategy but nothing around race and ethnicity apart from a token line about increasing the participation of Asian players. This is a selective and flawed approach appearing to assume no change is necessary on race.

• See earlier response to FA, but it is crucial that the democratic processes of voting are open and trans-‐parent and BME personnel working in other Football related settings are given recognition for their transferrable skills. The Equality Monitoring Tool needs to address the important issues of whiteness and gender, and whether there are other implicit processes to access; in terms of masons, political associations and networking.

39 Continuing to promote open and transparent processes in advertising for and recruiting their staff and volunteers.


40 Supporting the recruitment of coaches and referees from diverse backgrounds including BAME communities, to ensure that we maintain 10% BAME coaches at Level 1, and seek to achieve 10% of referees from BAME backgrounds nationally (whilst reflecting local demographics across the County FAs).

• Poor: Why only level 1 when point 25 above refers to level 1 and 2 which are both delivered by the county FA? Could it be because the data is skewed by professional players? In terms of referees see point 28 above. The plan is wholly inconsistent with the FA proposal and clearly has not been checked

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• We need to include the Youth Award, and targets and pathways to Level 3 through the Regional Managers and national targets at Level.

41 Supporting the delivery of targets for the number of female coaches and the number of disabled coaches as per the new FA Coaching Strategy.

• See point 26 above

42 Supporting the recruitment and talent development of Asian boys and girls.

• Repeat of point 29 above however how does this fall into widening the diversity of football’s workforce?

THE PREMIER LEAGUE: EDUCATION

43 Introducing social media guidelines for all players and other club staff.

• Poor: Only guidelines? Are there sanctions for failing to adhere to these? The Premier League issued clubs with guidance for social media in July 2012. Is this action point retrospective? This fails to take into account of the new CPS guidelines with respect to being careful not to prosecute every infraction and be cognisant of the right of the individual to the right of free speech guaranteed under article 10 of the European Convention on Human Rights (ECHR).

44 Working with the PFA and LMA to provide mandatory induction arrangements for players and managers arriving fresh to English football and the British cultural environment.

• Inadequate: This suggestion is patronising and potentially discriminatory, and makes the assumption that it is “foreign players” who fail to understand the British cultural environment rather than the “English players” who fail to address and respect the ethnicity, religion, and cultural norms of players coming to the UK. To attribute issues of discrimination in English football to overseas players and managers is far too simplistic. How do you explain John Terry? Paolo Di Canio has played and managed in this country for a number of years. Would an “induction” to British society have stopped him calling one of his players by his skin colour 12 years on? It appears that the football authorities don’t want to take responsibility and therefore look to blame “outsiders”. To treat all international players in this manner is in itself discriminatory and contrary to the EQA 2010 unless a “justification” can be lawfully made in defence. There are also a number of logistical issues for such a policy. An Anti racism induction course with refresher courses for all players, managers, coaches and referees is by far the best solution irrespective of race or nationality.

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• This only tackles a small part of the question. The challenge is to develop core trans-‐cultural competences for all personnel. However we agree that there is a need for education around whiteness and British-‐ness in terms of race and racism from the cognitive thought process, to the behaviour to the alienation and exclusion that manifest in the institutions of sport.

45 Ensuring mandatory learning and development provision within its clubs is provided in partnership with the PFA and LMA.

• Poor: For whom? All staff? The Board? What provision will be mandatory? Lacks specificity. • This is very loose and unspecific, it may be useful starting from the audit the learning gaps in

terms recruitment, selection, staff development and mentoring from administration, playing, coaching and management.

THE PREMIER LEAGUE: CULTURAL CHANGE

46 Promoting the ‘Crowd Management Measures’ – Good Practice guide to its clubs.

• See point 11 above • This is so unclear, and runs the potential risks of old cultural practices dictating good anti-‐

discriminatory practices.

47 Working with the other football organisations, Kick It Out and the fans groups (including FSF, LPF, GFSN and SD) to review and improve the impact of current awareness and education campaigns amongst fans.

• Satisfactory: Seems logical however no clear actions stated. • It is crucial that we work to ensure that Football Organisations, Kick it out and Fan groups

confront the historical and traditional forms of whiteness that alienates other communities.

48 Supporting KIO to conduct a major consultation with fans and fan groups to create a better understanding of their views and attitudes and establish the scope for engaging the fair-‐minded majority in self-‐policing fan behaviour.

• Satisfactory: Talking to fans groups is a positive step. However the rest of this point is speculative.

49 Reviewing the impact of the new training module for stewards.

• Satisfactory: Without knowing the content of the module this seems logical. However how do they intend on reviewing impact?

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50 Adopting and sharing best practice in stewarding with a particular focus on coordinated action to deal with discrimination.

• Satisfactory: Again seems logical however who would co-‐ordinate this? Again we appear to be discussing good practice rather than specific policies or indeed sanctions for failure to adhere to policies. The adoption of “good practice” requires identification of what this is and how stewards are supposed to identify perpetrators of racist abuse in the crowd and report them effectively without endangering their own safety. Smart phone video/camera technology could assist but would need to be resourced and be used effectively by stewards and clubs consistently.

51 Reviewing the Equality Standard for Clubs to ensure that it addresses the full range of equality issues and sets targets for Clubs to achieve the standards, including equality monitoring.

• Satisfactory: Who will undertake this review? What is the deadline to meet targets? What are the sanctions if they are not met? Surely there should be a mandatory level. It appears that only 8 Premier League clubs have engaged in this process!

• This needs to be linked to clear strategic targets.

52 Creating an explicit Equalities theme in Club and Premier League community activity, extending it beyond the widely accepted requirements on race and gender to homophobia and faith inclusion and anti-‐discrimination as well.

• Satisfactory: Clubs should be addressing these issues however our concern is when all these issues are grouped together none of them are understood or addressed in any real detail. Indeed that is a concern with this whole document which dilutes each respective aspect of unlawful behaviour and discrimination.

53 Aligning the Premier League's Equality Standard to The FA's LGBT, gender equality and disability action plans where relevant.

• Satisfactory: Again a logical step however we fail to see how this will have any real impact on the issues surrounding discrimination in football. Who will have responsibility for this and when will it occur? Once again no line of accountability and no time lines are set.

THE PREMIER LEAGUE: REGULATION AND REPORTING

54 In conjunction with the PFA, LMA and Clubs, ensuring that players, managers and staff understand how to report their concerns about alleged discrimination.

• Good: Seems logical however they won’t report discrimination if they don’t feel safe to do so or that no action will be taken. A unified system of reporting is essential with clear lines in each organisation of where responsibility lies.

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55 Reinforcing the instructions via PGMO to match officials of the importance of discrimination issues and the relevant reporting procedures.

• Satisfactory: A logical step however again not really a clear action designed to deal with the issues.

56 Investigating new technologies to assist with reporting incidents in stadia.

• Poor: Why is this relevant? It already appears to be used to good effect.

57 Reinforcing the guidance to Clubs to ensure that effective and efficient systems exist for reporting incidents in and around match days.

• Poor: Not committed to by the Football League. Do their clubs have this guidance? Again the MacPherson definition and Crime and Disorder Act 1998 need to be the common standard of practice and understood and implemented by all concerned.

58 Reviewing the range of sanctions employed by Clubs with a view to improving consistency.

• Poor: Sanctions employed by clubs for what? Should the Premier League not dictate the sanctions to ensure consistency? Clubs must receive a directive from the Premier League that racial abuse and other forms of unlawful discriminatory abuse must be treated automatically as gross misconduct by each club. This would avoid the shambolic and disgraceful conduct of Chelsea FC and Liverpool FC openly supporting the alleged perpetrators of racial abuse.

59 Reviewing and where necessary improving the reporting and analysis of in-‐stadium offences, to assist an assessment both of the complaints processes and of subsequent actions.

• Good: Who will review this? How will this be reported? Time scale? More detail needed. • Section 54 to 59 needs to be re-‐considered in light of AC Milan and the response from

Blatter, and will needs to consider issues of safeguarding, civil rights and criminal justice.

60 Working with the Police and the prosecuting authorities to ensure that offensive and insulting language and behaviour at football grounds and in other football-‐related environments is identified and dealt with appropriately.

• Poor: What is meant by “appropriately”? Vague! In London the SBL are promoting a London Race Hate Crime Football Forum to be established by the Metropolitan Police to which all London clubs, the FA, PFA, Premier League, CPS, Mattabe (GB), Community Support Trust (CST); SBL: Magistrates Association and Victim Support etc would be invited to attend on a regular basis. This could be replicated throughout the various FA regions as a model of good practice to combat hate crime and anti-‐Semitism.

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61 In conjunction with the PFA and LMA, establishing and delivering confidential support structures for players, managers and staff to use when incidents occur, to encourage the formal reporting of incidents.

• Satisfactory: An important point however again little detail included on how this will be implemented. The SBL believes that it is inevitable that BAME players will require a BAME support group and network throughout Europe to work alongside current structures so they have confidence to disclose incidents of racial abuse and discrimination and receive effective support.

THE PREMIER LEAGUE: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

62 Continuing to promote open and transparent recruitment processes in recruiting the football workforce including support for mentoring in relation to work placements in football, such as Kick It Out’s mentoring programmes.

• Repeat of point 21 above • This needs to be linked to the strategic audit.

63 Working with black players and their representatives to identify their educational and career progression needs, including supporting and implementing programmes such as COACH to capacity build coaches from Black, Asian, and Minority Ethnic communities, with higher level qualifications and experience to challenge for roles in the Professional game.

• Satisfactory: COACH provides BAME coaches with support to gain qualifications and experience however ex professional BAME players have easy access to this but are still not getting opportunities at the top level. Why are they not completing these qualifications? Why are those who attain the qualifications not getting the opportunities at the top levels? There is no avoidance that the racism encountered by BAME coaches at all levels is not being addressed by this plan. Targets, sanctions and education are required with a clear implementation of the “Rooney rule” and other measures of positive action under the EQA 2010 are required immediately to redress this institutional racism which is a huge waste of talent in the game.

64 Completing the Equality monitoring tool to provide accurate statistics on the Premier League staff, Boards and membership etc.

• Repeat of point 3 above • It is important that the Premier audit the staff in the Academy, and the potential

opportunities with the new EPPP programme.

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THE FOOTBALL LEAGUE: EDUCATION

65 Introducing mandatory ‘minimum standard’ Club codes of conduct with a mechanism for sanction, should Clubs fail to implement them.

• Satisfactory: Why is this not included in the Premier League’s commitments? What are the minimum standards? Who will decide these? What is the mechanism for sanctions being imposed?

66 Introducing social media guidelines for all players and other club staff.


67 Working with the PFA and LMA to provide mandatory induction arrangements for players and managers arriving fresh to English football and the British cultural environment.


68 Ensuring mandatory learning and development provision within its clubs is provided in partnership with the PFA and LMA


THE FOOTBALL LEAGUE: CULTURAL CHANGE

69 Promoting the ‘Crowd Management Measures’ – Good Practice guide to its clubs.


70 Working with the other football organisations and Kick It Out and the fans groups (including FSF, LPF, GFSN and SD) to review and improve the impact of current awareness and education campaigns amongst fans.


71 Working in conjunction with Kick It Out to set targets for its clubs to achieve the various levels of the Equality Standard.

• Satisfactory: A consistent standard should be agreed for all football league clubs to achieve by a specific date. This should also be imposed for Premier League Clubs.

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72 Reviewing the impact of the new training module for stewards.


73 Adopting and sharing best practice in stewarding with a particular focus on coordinated action to deal with discrimination.

• Repeat of point 50 above • Points 66-‐73 need clarification.

74 Delivering on relevant actions from the LGB&T, gender equality and disability equality action plans.

• Satisfactory: The Premier League only commits to aligning their equality standard to the FA LGB&T, gender equality and disability action plans where relevant. What actions will the Football League deliver on? How? By when?

THE FOOTBALL LEAGUE: REGULATION AND REPORTING

75 In conjunction with the PFA, LMA and Clubs, ensuring that players, managers and staff understand how to report their concerns about alleged discrimination.


76 Reinforcing the instructions via PGMO to match officials of the importance of the issue and relevant reporting procedures.


77 Investigating new technologies to assist with reporting incidents in stadia.


78 Reviewing the range of sanctions employed by its clubs with a view to improving consistency.


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79 Reviewing and where necessary improving the reporting and analysis of in-‐stadium offences, to assist an assessment both of the complaints processes and of subsequent actions.


80 Working with the Police and prosecuting authorities to ensure that offensive and insulting language and behaviour at football grounds and in other football-‐related environments is identified and dealt with appropriately.


81 In conjunction with the PFA and LMA, establishing and delivering confidential support structures for players, managers and staff to use when incidents occur, to encourage the formal reporting of incidents.

• Repeat of point 61 above • Points 75-‐81 need more details.

THE FOOTBALL LEAGUE: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

82 Continuing to promote open and transparent recruitment processes in recruiting the football workforce including support mentoring in relation to work placements in football, such as Kick It Out’s Mentoring programmes


83 Supporting and implementing COACH and other programmes to capacity build coaches from Black, Asian, and Minority Ethnic communities, with higher level qualifications and experience to challenge for roles in the Professional game.

• Repeat of point 63 above however the Football League do not commit to working with black players and their representatives to identify their education and career progression needs. This is a major omission by the Football League. There is a failure across the whole of football to promote academic excellence within football academies and within football clubs generally. The failure to promote education is a major disadvantage for all players, and especially for BAME players given the racism they face in the football employment market.

84 Reviewing the recruitment processes for Managers and Coaches and developing a voluntary code, based on a set of principles for recruitment, to be considered by its clubs.

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• Satisfactory: Repeat of point 23 above However the Premier League fail to commit to this! They appear to be completely opposed to even consider never mind implementing the “Rooney Rule”.

85 Completing and ensuring that the Clubs complete the Equality monitoring tool to provide accurate statistics on their staff, Boards and membership etc.

• Satisfactory: The Football League commits to ensuring clubs complete the monitoring tool however the Premier League does not! This is a ridiculous anomaly that cannot be maintained if the Premier League is to sign up to any meaningful change to tackle racism in the game. The monitoring tool cannot provide an accurate picture without all the relevant information.

• Points 81-‐85 are similar to the FA and are feedback, but there is far greater institutional barriers in the Premier Game over the last twenty years, reflects qualitatively different institutional issues.

THE PROFESSIONAL FOOTBALLERS ASSOCIATION: EDUCATION

86 Developing and delivering equality learning (in conjunction with the Leagues) as part of the youth development modules for scholars.

• Good: What will this entail? When/how will this be implemented? How will this is assessed? As discussed earlier short term education programmes may not affect attitudinal change however it shows the young players that these issues are important and relevant to them.

• Having worked with the PFA, being employed as a tutor, we need to influence the educational programme especially in terms of developing a equality programme for educational delivers and an a mentoring programme for BME scholars to have clearer career aspirations.

87 Developing and delivering equality learning (in conjunction with anti-‐discrimination partners, and Leagues) as development for senior players.

• Satisfactory: Educating senior players is a more complex process as they have now “made it” as professionals. Their main influencing factors are senior players and staff at the club. We would suggest that this would have limited affect.

• From my work at Kick it out this programme is now being introduced by a company who will need our support around developing some of the key trans-‐cultural competencies to develop BME player’s skills in areas of leadership and mentoring to make the transition to positions as coaches and managers. BACA Audit reviews some interesting feedback in relation to the lack of confidence in current equality programmes in the professional and grass-‐roots game.

88 Supporting the introduction of mandatory induction arrangements to support players who are new to English football and the British cultural environment.

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THE PFA: CULTURAL CHANGE

89 In conjunction with the Leagues and clubs, establishing and delivering confidential support structures for players to use when incidents occur, to encourage the formal reporting of incidents.


90 Supporting standard clauses that address discriminatory language and behaviour, in players’ contracts.

• Satisfactory: This is not committed to by the FA, Premier League or Football League. What would be the punishment be if the player was found guilty (and by whom?) of using discriminatory language or behaviour? As the players are assets clubs are only likely to enforce this clause for their own benefit i.e. if they want to get rid of a player. This needs to be a mandatory requirement of all members of the PFA but needs to be enforced consistently by clubs. The failure of Chelsea strongly suggests there was a minimum punishment if any at all. 91 Delivering on relevant actions from the LGB&T, gender equality and disability equality action plans.


THE PFA: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

92 Supporting and implementing COACH and other programmes to capacity build coaches from within Black, Asian, and Minority Ethnic communities.

• Repeat of point 63 above however the PFA do not commit to “working with black players and their representatives to identify their education and career progression needs” which is a significant omission given this is the player’s union.

93 Working with FA, Premier League and Football League and their clubs along with LMA to ensure pathways and opportunities are accessible for all professional players in order to access coaching and management positions further to achieving relevant qualifications.

• Poor: Neither the Premier League or the Football League commit to this (although they do the previous point). Therefore contention seems to fall around ensuring opportunities are

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available for BAME coaching and management positions. This is why a version of the Rooney Rule should be introduced.

94 Advocating to The FA for the continued increase of BAME adjudicators on the list of panel members, from which Regulatory Commission members are selected.

• Good: Although the FA themselves do not appear to specifically commit to this! Again there is a lack of consistency in the plan. The FA ought to have included this commitment and provided a target with a timeline. Again, the under-‐representation of BAME decision makers in the regulatory process suggests the non too subtle refusal to permit access to one of the key points of power and influence in the game 95 Completing the Equality monitoring tool to provide accurate statistics on the PFA staff, Boards and membership etc.


THE PFA: REPORTING

96 In conjunction with the Leagues and Clubs, ensuring that players understand how to report their concerns about alleged discrimination.

• Repeat of point 75 above • Point 91 to 95 makes no reference to the importance of the Rooney Rule, the work done by

Paul Davis and the role of the Black player’s forum that has been done in relation to the last six years. It is crucial we examine the data and statistics in terms of the wider institutional changes that are needed.

LEAGUE MANAGERS ASSOCIATION: EDUCATION

97 Supporting the introduction of mandatory induction arrangements for managers and coaches who are new to English football and the British cultural environment.


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THE LMA: CULTURAL CHANGE

98 Supporting standard clauses that address discriminatory language and behaviour, in managers and coaches’ contracts.


99 Delivering on relevant actions from the LGB&T, gender equality and disability equality action plans


THE LMA: WIDENING THE DIVERSITY OF FOOTBALL’S WORKFORCE

100 Supporting and implementing COACH and other programmes to capacity build coaches from Black, Asian, and Minority Ethnic communities, with higher level qualifications and experience to challenge for roles in the Professional game.

• Repeat of point 91 above 101 Ensuring that the LMA staff complete the Equality monitoring tool to provide accurate statistics.


THE LMA: REPORTING

102 Ensuring that managers understand how to report their concerns about alleged discrimination.


103 Establishing and delivering confidential support structures for managers and coaches to use when incidents occur, to encourage the reporting of incidents.


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THE PROFESSIONAL GAME MATCH OFFICIALS LTD: EDUCATION

104 Implementing mandatory training for all PGMOL match officials and requiring referees on this list to undertake refresher training every three years.

• Good: Who will deliver this? What will it include? From when will this become mandatory? This must include how to deal effectively with racist and anti-‐Semitic incidents form both players, and fans. Where there is systematic and/or prolonged racial abuse of BAME players from any section of the crowd the referee must be given the power and directive to halt the match, remove the players from the field and abandon the match. The safety of players must not be compromised in the interests of the financial cost to the clubs of abandoning the match, awarding the points to the opposing side or playing the match again.

THE PGMOL: REPORTING

105 Ensuring that referees understand the definitions in The FA’s Regulations, which reflect the Equality Act, 2012 and their obligations in relation to reporting misconduct and or discrimination.


THE PGMOL: CULTURAL CHANGE



THE REFEREES ASSOCIATION: EDUCATION

107 Working with The FA to implement mandatory equality training for referees and requiring referees to undertake refresher training every three years.


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THE REFEREES ASSOCIATION: REPORTING

108 Ensuring that referees understand the definitions in The FA’s Regulations, which reflect the Equality Act, 2012 and their obligations in relation to reporting misconduct and or discrimination.


THE REFEREES ASSOCIATION: CULTURAL CHANGE

