This document provides a point-by-point response from organizations including the Society of Black Lawyers and the Association of Black Coaches to the Football Association's 92-point plan on inclusion and anti-discrimination. It expresses support for establishing an independent advisory board and collecting diversity data, but calls for improvements to equality education programs, monitoring, and handling of reported incidents. The response emphasizes the need for democratic processes, independent oversight, and linking initiatives to legislation to truly address issues of underrepresentation and discrimination in English football.

1. 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.
1

2. 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
2

3. 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-­‐
3

4. 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
4

5. 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
5

6. 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.
6

7. • 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?
7

8. 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.
8

9. 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
Level
2:
9.2%
of
6,373
coaches
were
from
black,
Asian
and
minority
ethnic
groups
Level
3: 4.2%
of
1,369
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?
9

10. • 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
10

11. 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
11

12. 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
12

13. 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.
• Repeat
of
point
21
above
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
13

14. • 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.
14

15. • 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?
15

16. 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.
16

17. 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.
17

18. 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.
18

19. 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.
• Repeat
of
point
43
above
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.
• Repeat
of
point
44
above
68 Ensuring
mandatory
learning
and
development
provision
within
its
clubs
is
provided
in
partnership
with
the
PFA
and
LMA
• Repeat
of
point
45
above
THE
FOOTBALL
LEAGUE:
CULTURAL
CHANGE
69 Promoting
the
‘Crowd
Management
Measures’
–
Good
Practice
guide
to
its
clubs.
• Repeat
of
point
46
above
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.
• Repeat
of
point
47
above
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.
19

20. 72 Reviewing
the
impact
of
the
new
training
module
for
stewards.
• Repeat
of
point
49
above
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.
• Repeat
of
point
54
above
76 Reinforcing
the
instructions
via
PGMO
to
match
officials
of
the
importance
of
the
issue
and
relevant
reporting
procedures.
• Repeat
of
point
55
above
77 Investigating
new
technologies
to
assist
with
reporting
incidents
in
stadia.
• Repeat
of
point
56
above
78 Reviewing
the
range
of
sanctions
employed
by
its
clubs
with
a
view
to
improving
consistency.
• Repeat
of
point
58
above
20