With the FIFA World Cup Qatar 2022 now less than 10 months away, teams are preparing to make key decisions about their stay in Qatar, including booking hotels, security and transport. However, the lack of engagement and transparency from football associations (FAs) so far suggests many teams are not yet fulfilling their responsibility to conduct meaningful human rights due diligence as required under the UN Guiding Principles.

Over the past year we have seen human rights gain prominence in the football world. Players, including Finnish captain Tim Sparv, have spoken out in support of migrant workers’ rights and national teams have also signaled their support for workers’ rights, with Denmark set to display messages of solidarity during World Cup matches and the Swedish team cancelling a training camp in Qatar where workers suffer systemic abuse. On a local level, clubs in Norway took concrete actions to support workers’ rights in Qatar and, most recently, the annual general meeting of FC Bayern was thrown into disarray when a fan group-tabled motion on the club’s continued sponsorship by Qatar Airways was not permitted a hearing.

In light of the Norwegian Football Federation hosting matches and training camps with serious human rights challenges, their newly formed Norwegian Ethics Committee expressed “[astonishment] NFF does not seem to have a stronger focus on due diligence methodology and risk analysis” and recommended “NFF acts as a ‘responsible consumer’ in connection with Norwegian participation in international events, by choosing suppliers who can demonstrate that they are working actively to avoid involvement in gross human rights and/or labour rights abuses.” While Norway did not qualify for the World Cup 2022, other FAs should look to this as a good best practice example, recognising and mitigating the risks of participation in international footballing events.

This increasing awareness of human rights in international football could signal a step-change in the sport’s attitude towards social responsibilities. This will be tested as teams’ itineraries are planned, hotels are chosen and transport is booked. All teams must embed human rights into their operations and conduct meaningful human rights due diligence to ensure they are not complicit in abuses. Evidence from our own data, research from partners on the ground and recent media reporting shows migrant hotel workers in Qatar are at high risk of serious labour abuses, even in hotels endorsed by FIFA to provide luxury match packages. Without effective due diligence, workers in hospitality, construction and other industries essential for the success of the World Cup will suffer human rights abuses.

Business & Human Rights Resource Centre has recorded 197 cases of alleged labour abuse against workers in Qatar since January 2016. Hospitality workers were affected in 20 cases and 24 cases involved security workers; transport workers were affected in 13 cases and cleaners in 25. Fifty-four reports were recorded over the past year alone and these numbers are very much the tip of the iceberg. In 62% (122) cases workers reported delayed or non-payment of wages, with health and safety concerns and poor living conditions cited in 28% (56) and 33% (65) cases. Additionally, news outlets and NGOs continue to raise the alarm about workers’ inability to change jobs and the payment of hefty recruitment fees.

With these well-documented abuses, it is surprising FAs have done little to engage with the human rights risks associated with the tournament. In December 2021, we asked the 12 qualified teams of the Qatar World Cup questions on their human rights risk assessments and due diligence ahead of travelling to Doha later this year. Disappointingly, we were met largely with silence. Only six of the 12 associations (Belgium, Brazil, Croatia, Germany, the Netherlands and Switzerland) responded to us with any information at all. More disappointingly, no association addressed the questions regarding risk assessment or due diligence in any meaningful detail. Disclosing this information would signal a welcome commitment to corporate transparency - accepted practice in other sectors and expected by stakeholders such as investors and sponsors.

Among the six which did not respond, FAs told us the questions were “irrelevant” or “inappropriate”. Concerningly, it appears only the minority are factoring human rights issues and due diligence into the process of choosing their base camp hotel and facilities.

Several responding and non-responding FAs referred to a group of hotels contracted by FIFA, from which they can shortlist preferences. In response to our questions, FIFA said it “includes human rights clauses in all its contractual relationships”. However, there is again a concerning lack of transparency regarding what is meant by such standards, guarantees and checks. It is also important to note reliance on FIFA’s process alone does not constitute adequate risk assessment or due diligence on the part of FAs. FIFA states these standards will be implemented through the Workers’ Welfare and Sustainability teams of the Supreme Committee and Q22. While it is encouraging that there will be a greater degree of oversight of this group of hotels in the run up to the World Cup, it is important to note the shortcomings of audits as a means for identifying and monitoring human rights violations as such process are top down and not worker driven.

Football associations, as well as other hotel guests, sponsors and the media, are in a unique position to pressure brands and companies to uphold human rights and labour rights standards in a country where workers all too often pay the price. FAs are at the very centre of the World Cup and are well-placed to trigger meaningful changes in Qatar across a range of industries. If they choose to engage seriously with human rights issues and conduct a transparent, thorough human rights risk assessment and a robust human rights due diligence process it could be transformative - resulting in tangible, positive impacts for the millions of workers at the centre of one of the world’s greatest sporting spectacles.

Updates

The Danish Football Association (DBU) provided a statement in response to the questions on 26 April 2022.

Following our outreach to the remaining qualified FAs by April 2022, only US Soccer and the Polish Football Federation responded.

Of the final teams to qualify, Football Australia and the Football Association of Wales provided information.

The English Football Association provided a statement in response to the questions on 27 July 2022.