The development of sports law has been driven by its increasing commercialisation: the more money in sport, the more the scope for professional advice and management to ensure that the sportsman as well as other stakeholders realise their objectives. This can also spawn a specialist sector of lawyers. The reality is that sport is a business; it is evolving into a distinct economic sector and major revenue earner in countries where its capacity to deliver this contribution has been recognised, harnessed and sustained.
Presently, it is difficult to measure the contribution of the sports sector to Nigeria's Gross Domestic Product (GDP) as sports is not currently listed as one of the forty six (46) activity sectors measured by statisticians in computing our GDP.1
The non-recognition of sports as an activity sector affirms the fact that sports in Nigeria is not yet a significant economic activity. However, it can be said that sports is covered under the arts, entertainment and recreation sector which contributed 0.20% to the rebased GDP in 2014. Moreover, the 2017 annual contribution was recorded at 0.23%, lower than the 0.24% recorded in 2016.2
One major reason why Nigerian sports sector is not fulfilling its potential is its constrained posture arising from structural issues. This typifies a 'vicious cycle' such as maladministration, poor funding, general neglect and poor atmosphere, resulting in unimpressive outcomes. There are various examples, including unfair contracts, deliberate breach of contracts by players and clubs etc.
There can be no investment if things do not improve thereby making it a "chicken and egg" situation. There are various ways our sports sector can be improved, most especially our football league. These includes: through sponsorship and commercial rights; broadcasting rights; image rights; eradicating corruption and doping scandal etc.
Who will bell the cat and how is such to be achieved? This article discusses the various ways towards increased attractiveness of Nigeria's most popular sport - football - to potential investors and other stakeholders whose support and collaboration would be valuable. What role can the instrumentality of law in advancing efficacy of prescribed/contractual obligations play in this regard?. We will preface our discussion with football regulatory framework.
Nigerian Football: Regulatory Architecture
The main body responsible for the regulation of football in Nigeria is the Nigerian Football Federation (NFF). Section 6(a) NFF Act3 saddles NFF with the responsibility to organise league and other matches for professional and amateur clubs in co-operation with the respective bodies recognised by the Association. However, the body responsible for the regulation of our football league is the League Management Council (LMC).4
Contracts between Players and Clubs
In Europe, the 'Bosman ruling' (given in 1995), enabled football players to leave clubs within the EU without requiring a transfer fee. Accordingly, players could see out their contracts and move to other clubs on free transfer.5 In light of this, the Federation Internationale de Football Association (FIFA) decided to make various provisions protecting players' contracts through the FIFA Transfer Rules (FTRs)
According to Article 13 FTR, any contract between professional soccer players and a club may only be terminated upon expiry of the term of contract or by mutual agreement. However, Article 14 FTR provides that a contract may be terminated by either party without any consequences either through payment of compensation or imposition of sporting sanctions where there is a just cause. Article 17 FTR goes further to state that when a contract is terminated without just cause, the person in breach will have to pay compensation.
The Dilemma - Contract Structuring in Nigeria
Sec 21(b) NFF Act states that there should be an appropriate, legally binding agreement between registered football clubs and professional football players who shall have the benefit of the services of legal advisers during negotiation. In practice, there seems to be many irregularities in the Nigeria sports sector and low awareness of the legal requirements, especially on the part of players.
For example, most football clubs take players from academies without the proper contractual agreements between the clubs and the players, meaning that the clubs do not in the real sense 'own' the player being sold to them because the contract is not well structured.6 In Brazil, a rule, 'Pele's law', was introduced in 1998 - it established that professional football players must enter into employment contracts with sports clubs that are in written form, specifying the names of the respective contracting parties and the due remuneration.7
On its own part, Rule 9.49, Nigerian Professional Football League Framework Rule 2014 (NPFLR), states that "a contract between a club and a player shall be signed in each case in the presence of a witness by the player; the player's parent if the player is under the age of 18 years; and an authorised signatory on behalf of the club." However, this does not seem to be widely observed in Nigeria.8 Hence, for any player whose club does not provide a valid contract then it is advisable that such a person should seek legal advice before embarking on any deal with the club.
Another major concern is the minimum wage football players are presumed to earn. Rule 9.42 NPFLR states that the minimum wage should not be less than N150,ooo per month. (It will not be surprising if) This rule has however been kept more in default than compliance.9 Although the NPFLR stated that any club that cannot meet this rule should not be allowed to participate in the league, it cannot be said to be so in reality.
Rule 9.51 NPFLR states that clubs shall submit to the LMC, copies of all contracts with players within five (5) days of their being entered into. This is another rule which is not often adhered to and hence there should be a financial penalty put in place for clubs that default. If any club cannot submit the contracts entered into with their players, then such a club should be banned from participating in the league for that season. The LMC is in pole position to ensure adherence to this rule.
It is advisable that contracts in Nigeria should be properly crafted with emphasis on typical clauses and the significance of such clauses. For example, what happens if a player gets injured? This brings to mind the issue of insurance scheme for players. Section 21(g) NFF Act states that every registered football club should have a satisfactory insurance policy put in place. Also, Rule 12.12 NPFLR recapitulates that clubs shall ensure that they maintain a medical insurance scheme approved by the LMC and comply with all relevant pension laws. This should not be surprising because players are to all intents and purposes, "employees" of clubs, and the latter are therefore obliged to also comply with (non-sectoral), generally applicable employer obligations. Recently NFF signed a five year partnership deal with Wapic Insurance Plc.10 Many insurance companies provide a wide range of products to football clubs such as Public Liability Insurance (PLI), Group/Personal Accident Insurance (GAI/PAI), Workmen Compensation Insurance (WCI), etc.
The PLI and PAI deserve special mention. For the PLI, a club can be held liable if it was negligent or failed to take reasonable care to prevent injury to members of the club, spectators and match officials or damage to property. This insurance is designed to pay compensation and legal cost that arises if the club or any of its members are found to be at fault.
For example, a player could be hurt after colliding with a goal post that was in a rusty, poor condition and with protruding metal hooks. The injury to the player may not have been more serious than it should have been but for the club's negligence in failing to ensure that the equipment was in a safe condition.
PAI is designed to provide compensation for players following injury whilst playing, training and travelling to and from an organised club activity. The club does not need to be negligent for a successful claim to be made. Benefits of such cover include quick settlement for injured players and this proves that the club has taken extra measures to protect its players. This should be a necessity for our football clubs as there are instances where players are involved in accidents as was the case in 2009 when several Zamfara United players were involved in a fatal accident that claimed the life of a player and an official. Unfortunately, none of the players were reportedly insured to cushion the effect of their misfortune (or indemnify the club in making payments to the deceased family or treating the injured survivors).11
Another example is if a player breaks his leg during a league match and as a result is signed off work for six weeks. By providing PAI, the player can claim his benefit whilst off work. The club is bound to pay him now as he suffered the injury in the course of his employment. Insurance then becomes useful to help indemnify the club of its financial losses incurred in paying the injured player.
According to Rule 6.10.4 NPFLR, "No Club shall employ any person as a manager or coach unless and until the terms of the managers or coaches employment is in a written contract of employment between the club and the manager/coach; and the managers or coaches contract of employment has been registered with the league". It should be noted the issue of clauses in contract affects the managers more because most times when the club does not perform as expected, they are the first to get fired. One notorious refrain in global football circles is that "there are two categories of managers: those fired and about to be fired".12 But the issue is even when their contract is terminated, why is it hard to compensate them in Nigeria?
This is completely in contrast with managers in England or Europe where most managers are compensated well after being relieved of their position, otherwise the managers will sue the clubs - and that may even cost more, hence the need to settle them quickly to avoid legal actions. Some examples include Rafa Benitez who signed for three (3) years, but was fired by Real Madrid after only 25 games in eight months, and compensated with ?7 million. Another example is Jose Mourinho who during his two stints at Chelsea was compensated with ?10 million euro each.13 Most recently, Antonio Conte of Chelsea was sacked and offered a compensation of ?9 million.
So why is it different with our Nigerian managers, even if given, the level of our soccer development the amounts will be drastically lower? This is even exacerbated by unfair dismissals that should attract punitive damages. For example, in 2013, the now defunct Sharks Football Club of Port Harcourt reportedly axed Augustine Eguavoen because he asked for a well-documented contract and officials of the club refused.14
Adherence to Contracts
Rule 9.45 NPFLR states 'that the terms of a contract between a club and a player shall be strictly adhered to and where a club fails to pay remuneration or entitlements due to players for a period of more than sixty (60) days, such club shall be liable to a deduction of a maximum of six (6) points and a further deduction of three (3) points for every further thirty (30) days for which the remuneration or entitlement remains unpaid'. This severe penalty is supposed to keep clubs on the straight and narrow but this has definitely not achieved its aim. Football clubs are employers and are bound by Nigerian employment law as everyone else. For example, the Labour Act (LA)15 may apply to the clubs' low level staff and junior ("apprentice") football players.
Section 9(4) LA states that no contract shall provide for the payment of wages at intervals exceeding one month unless the written consent of the State Authority (Governor or Administrator of a State) has been previously obtained.
With the above provision, the question comes to mind: why are professional football players sometimes owed salaries for several months? For example, players of 3SC Football Club, Ibadan were recently owed five (5) months' salaries, etc.16 The severity of this could be seen in some cases where Nigerian players enter into 'slavery' contracts with foreign clubs including in countries with poorly developed soccer leagues just to enable them escape the hardship from our league as was seen in the case of Michael Uchebo.17
The answer is not far-fetched. This could be attributed to the fact that they did not or are unable to seek professional advice prior to entering into these engagements with the respective football clubs. The reluctance of clubs to pay players whose contracts have been terminated is alarming, albeit section 11(7) LA provides that all wages payable in money shall be paid on or before the expiration of any period of notice. Furthermore, the contracts if well drafted should have provided for post termination scenarios.
This cannot be said to be practiced in Nigeria as most players are rarely paid their wages after being offloaded by their clubs and that is due to their inability to make sure that they signed enforceable contracts. Contrast with the recent case between Barcelona and Neymar; Barcelona declined to pay ?26 million bonus included in Neymar's contract renewal signed in 2016 after completing his world-record transfer to Paris Saint-Germain before the end of his Barcelona contract on the ground that he had not earned same.18
Contracts with Agents
Football agents handle all aspects of a player's career, from helping to decide which club they choose to play for, to ensuring they are being paid enough for their services. They also help to manage transfers on behalf of their players, negotiating contract renewals, handling marketing and media enquiries, including endorsements and sponsorship opportunities, supporting players with personal issues, and handling any grievances they have with the club.19 It is thus wise to always have a representation agreement with such agents which outlays the footballer's ambition, professional development and growth plan amongst others. The arrangement which should be underpinned by mutual trust and respect, enables the footballer focus on the technical aspect of building his career whilst the agent essentially looks after the commercials, in the best interests of his client.20 It has been stated that "an agent should be a (football) player's best friend, but unfortunately, that is not always the case." 21
Rule 2, FIFA Regulation on Working with Intermediaries (FRWI)22 clearly states that players and clubs are entitled to engage the services of intermediaries when concluding an employment contract and/or a transfer agreement. For the sake of clarity, clubs and players should specify in the relevant representation contract the nature of the legal relationship they have with their intermediaries, for example, whether the intermediary's activities constitute a service, a consultancy or any other legal relationship. According to Rule 5(2) FRWI: the main points of the legal relationship entered into between a player and/or club and an intermediary shall be recorded in writing prior to the intermediary commencing his activities.
The representation contract must contain the following minimum details: the names of the parties, the scope of services, the duration of the legal relationship, the remuneration due to the intermediary, the general terms of payment, the date of conclusion, the termination provisions and the signatures of the parties.23 We have presumed that such agent is duly licensed, otherwise there is no basis for even discussing engaging such agent. If the player is a minor, the player's legal guardian`s shall also sign the representation contract in compliance with the national law of the country in which the player is domiciled.
Paragraph 8 NFF Strategy Guidelines states that "All NFF Executive Committee Members, NFF Management and Staff, State Football Association Chairmen and their respective Board Members, Club Chairmen and Officials, Coaches and all other Football Officials are hereby directed to desist from acting as Intermediaries (Agents/Managers) to players forthwith". This is obviously to prevent conflicts of interest, as coaches could select players based on "marketing" considerations, rather than their performance or current form vis a vis other players appropriate for the immediate match.
Increasing Sports Attractiveness to Investors - the Way Forward
Investors are usually attracted to business opportunities with potential for high returns, and Nigerian football sector cannot be different. The Nigerian sports sector could easily fill in into the investors' port-folio provided that certain standards are established and maintained. Some of which include:
- Sponsorship and Commercial Rights
Globacom and other corporations have served as sponsors in one way or the other in the Nigerian football sector. Sponsorship is when a business provides funds, resources or services to a club in return for some form of rights with the club that may be used to help the business commercially. In Nigeria, one of the major oil giants, Aiteo currently sponsors Nembe City FC of Bayelsa in addition to sponsoring Nigeria's oldest football competition, the Aieto Federation Cup. As at date, its investment in football is estimated to be N2.5 billion.24
We will have more sponsorships and for greater monetary value if and when things improve, and our soccer has positive image that investors can identify with. Branded jerseys was a late arrival in Nigeria. They tended to focus more before on sponsoring telecast of international matches featuring Nigerian teams (with the 'Super Eagles' enjoying preferential treatment), foreign leagues or club competitions like European and CAF Champions League. It is hardly surprising that leading Nigerian home based players rarely leverage and make significant income from their image rights.
This is in contrast with European clubs where the monetary value of their sponsorship is very high. Some examples includes deals between Real Madrid and Emirates Airways who renewed their shirt sponsorship deal in a new deal worth £350 million for five years while Manchester United have a deal which is worth £310 million for five years with Chevrolet.25Also Stadium naming rights like Man City's 'Etihad' and Arsenal's 'Emirates' is as a result of the deals entered between both clubs and their sponsors.
In 2017, the LMC signed a deal with Nigerian Television Authority (NTA) which will include setting up a joint venture production company to handle broadcast and distribution of league matches in Nigeria.26 According to reports, LMC will oversee the production and distribution of rights while NTA will provide eight (8) Out Side Broadcast (OB) Vans, which have HD facilities for this purpose. Super-Sports (a DSTv channel) and LMC had previously explored a deal worth N5.4 billion to cover 2015 t0 2017 but this reportedly fell through because DSTV would have needed to buy broadcast rights and still bear 100% responsibility for the production.
To illustrate its increased value, BSkyB and British Telecoms (BT) gave the FA a whopping £5.1 billion to secure the broadcast right for the 2016-2019 Premier League seasons.27 Coming closer home, the South African league is one of the most viewed leagues in Africa and this is made possible because of their broadcast deal which was also with Super-Sports spanning from 2012 to 2017 worth over $227.5 million. No wonder they were the only African league to be listed in the top 25 amongst the best leagues in the world by Sport Intelligence in 2013.
- Image Rights
In order to understand what image rights are, it is probably best to understand where they fit into the wider football industry. Unsurprisingly, clubs have traditionally paid their players solely for playing football. This relationship is evolving.
As commercial drivers push football into the entertainment and brand space, clubs are looking for a variety of ways to monetise and grow their revenue base. As such, clubs are entering into a multitude of commercial partnerships whereby brands want to be associated with clubs and their high-profile players. For example in 2016, Lionel Messi was involved in prominent advertising campaigns with Pepsi, Gillette and Turkish Airlines; Forbes valued his 2016 endorsement fee income at ?28 million.
Taking control of the image rights of the footballers is a significant aspect of the relationship between the footballers and their clubs, as both parties are clearly aware of the potential amounts of monies involved.
In 2006, David Beckham demanded that Real Madrid should give up their 50% share of his image rights which would have thus given him 100% of all profits from the commercial exploitation of his image. Real Madrid refused, causing him to leave the club. Later, he signed a five year contract with US club LA Galaxy worth ?128 million. The contract granted him the complete control of his image rights. David Beckham's case is exemplary because as a result of the deal, he was able to control how and when his image is used particularly in endorsements and sponsorship deals. This shows a shifting of powers between the club and the footballers. In contrast, nothing much is happening in this space in Nigeria, except for few Super Eagles' players being brand ambassadors like Mikel Obi, Victor Moses and some ex- players too, like Jay-jay Okocha and Victor Ikpeba.
The issue with Image Right Contract (IRC) is that most players do not fully understand the terms of the contract, hence likely to erroneously breach them and losing the contract. Maybe due to the state of our football, there is no clarity on image rights utilisation as between Nigerian clubs and their players.
- Standard Structures and Security
Section 21(k) NFF Act encourages registered football clubs to build and own standard football pitches according to FIFA minimum specification within 7 years and they will be disqualified if they fail to comply with this rule. A look at South Africa will show the essence of having standard infrastructures as this has helped enhance the game of football there.
There is also section 12 NFF Act which stipulates that there should be security arrangement for football matches always. This is really necessary because over the years, there were cases of fans violence which caused several casualties due to porous security arrangements. With the tightening of security, more people will come and watch their teams play without the fear of being attacked.
- Eradicating Corruption
Corruption in football is not a new issue, and has been rife in football circles, with concomitant action to stamp it out. Former president of FIFA Sepp Blatter was under investigation and has been banned from all football activities for six years. Jerome Valcke, former Secretary-General FIFA, Michel Platini former President of UEFA were similarly sanctioned. Dr. Amos Adamu who was filmed agreeing to an illicit transaction by undercover reporters which led to his exit from FIFA and CAF Committee and Board positions.28
Recently in Nigeria, a video went viral showing the Nigerian assistant coach Salisu Yusuf allegedly taking bribes and also in Ghana, top officials and a referee were caught on camera collecting bribe and have been suspended from all football related activity.29 Until corruption is eradicated, our football will hardly progress as there will be continuous match fixing and partiality. Corruption can also be seen in terms of home teams always winning matches, intimidation of match officials, bribe related issues and poor refereeing decisions, etc making the league void of excitement.
Another expression of corruption in Nigeria has to do with misappropriation of funds, brazen theft, lack of transparency and misplaced priorities in spending, etc. One school of thought is of the view that the contest for sport administration is often driven my selfish motives - not of service - but to have access to funds voted for sports (sponsorship fees, government grants and FIFA/CAF grants).30
Arbitration, Dispute Resolution Chamber
Looking at arbitration in the football sector, the leadership tussle between the FIFA recognised Amaju Pinnick led NFF and Chris Giwa's factional board which approached Nigerian courts and recently obtained favourable verdict of the Supreme Court (SC) comes to mind. There was however an objection to this verdict stating that since the above matter had previously been settled by the Court of Arbitration for Sports (CAS) in favour of Pinnick then the verdict was null and void.
However, Nigeria risked suspension from international soccer if effect was given to the judgment as FIFA statutes frowns at municipal court interference in football matters, reserving exclusive jurisdiction to the CAS. Given that decisions of courts must be obeyed, the finality of SC decisions coupled with potential contempt proceedings for disobedience of court orders, the question of how to proceed - comply with domestic court decision or ignore same to avoid FIFA sanctions becomes a herculean one as FIFA gave the NFF until the 20th of August 2018 to put its house in order or be banned from football activities which the NFF has duly complied it.31
It should be noted that any individual or legal entity with capacity to act may have recourse to the CAS. These include athletes, clubs, sport federations, organisers of sports events, sponsors or television companies. The party wishing to submit a dispute must send the CAS Court Office a request for arbitration (ordinary procedure) or a statement of appeal (appeals procedure), the contents of which are specified by the Code of Sports-Related Arbitration(CSRA). According to Rule 47 CSRA; in the case of the appeals procedure, a party may lodge an appeal only if it has exhausted all the internal remedies of the sports organisation.
Regarding Nigerian football league, Rule 9.54 NPFLR iterates that any dispute or difference between a club and a player not otherwise expressly provided for in the NPFLR may be referred in writing by either party to the LMC for consideration and adjudication in such manner as the Board may think fit. Thus, any official or player of a club who intends to declare a trade dispute with a club over unfulfilled contract agreement or conditions of service shall in the first instance give 45 days' notice to the club management stating grounds of dispute.
All disputes arising from transfer of players, contracts, etc. shall be referred to the Dispute Resolution Chamber (DRC) for adjudication.32 Decisions of the Arbitration Committee shall be final and binding on all parties concerned. Failure by any club to comply with any decision of the Arbitration Committee within 30 days shall cause the club to be expelled from the league.
There have been a number of relatively recent cases where a player has terminated his contract unilaterally by taking advantage of Article 17 FTR.
Andy Webster v. Midlothian,33which saw Andy Webster move to Wigan Athletic from Heart of Midlothian for a "mere" sum of £150,000 equivalent to the year`s salary he had remaining on his contract, has been overtaken by a more in-depth decision in Matuzalem v. Shaktar Donetsk,34 which has swung the pendulum back in favour of the clubs. The latter case arose after Matuzalem, the Brazilian captain and top scorer at Shakhtar Donetsk, unilaterally ended his contract and moved to Real Zaragoza, which subsequently agreed his transfer to Lazio in Italy. Shakhtar took the case to FIFA and then appealed to CAS after FIFA` s ?6.8m (£6m) compensation award. But CAS raised Shakhtar`s compensation as its decision took into account the value of the player to his former club, his salary, the difficulty he placed them in with the timing of his departure before deducting the salary Shakhtar would no longer have to pay him. CAS calculated this amount at more than ?12 million. The decision removes the harmful effect of the Webster decision. Players cannot now assume they can walk out on a club and only pay the residual value of their contracts. CAS will consider compensation based on the value lost to the club.
Just as other professionals like doctors, lawyers and engineers depend on their jobs for their daily bread, so should footballers also be able to rely on their skills for income to help provide for their families. This can only be possible if Nigerian Football Clubs pay these players regularly. It is therefore important for players to have requisite legal and professional representation/support in concluding or renewing their contracts with football clubs, whether Nigerian or foreign.
Regarding improving the attractiveness of our league for foreign players as was the case in the '80s, there has to be 'right and proper' administration in the Nigerian football sector. This is apparently the spring board upon which other factors such as having a good broadcasting deal, sponsorship and image rights of players can be effected.
2. National Bureau of Statistics 2017: Nigerian Gross Domestic Product Report (Q4 & Full Year 2017) at page 15 under the Arts, Entertainment and Recreation Sector, February 2018
3. Cap. N110, Laws of the Federation of Nigeria (LFN) 2004.
4. NPFLR 2014
5. If a player is no longer under contract and is transferred from a club in one member state of the European Union to a club in another member state, then it is no longer possible to obtain a transfer fee. But this only applies if the player is also a national of one of the EU member states. If a player is transferred from one English club to another then it is possible to obtain a transfer fee: culled from The Impact of Bosman Ruling on the Market for Native Soccer Players.
6. Kolade Oni, 'NFF`s Report on Emem Eduok Transfer Saga Out Thursday', Goal.com, 12 February 2015: (www.goal.com/en-ng/news/4111/npfl/2015/01/7758992/nfls-report-on-emam-eduok-transfer-saga-out-thursday ) (accessed 14.7.2018)
7. The Sports Law Review 2015 pg. 33
8. Okoronkwo John, 'Footballers Play in NPFL Without Valid Contracts', Independent.ng, 1 April 2017: (https://independent.ng/footballers-play-in-npfl-without-valid-contracts ) (accessed 3.8.2018)
9. Ibitoye Shitu, 'How Footballers are Frustrated in Nigeria', NaijaSports, 18 March 2017: (http://www.naijasports.ng/775087-feature-bad-scene-nigerian-football . html/775087 )(accessed 12.7.2018)
10. Johnny Edward, 'NFF, Wapic Insurance Sign Five Year Partnership Deal', CompleteSports, 19 January 2018: (https://www.completesportsnigeria.com/nff-wapic-insurance-sign-five-year-partnership-deal/ ) (accessed 6.8.2018)
11. Samm Audu, 'Nigerian Club Official Killed, Several Players Injured in Another Crash', Goal.com, 20 February 2009:(www.goal.com/en/news/89/africa/2009/02/20/1119580/nigerian-club-official-killed-several-players-injured-in-another-crash ) (accessed 12.7.2018)
12. James Phillips, 'Premier League 2018/2019: Which Managers do Bookies Think Will Still be There Next Season?', DailyStar.com, 26 March 2018: (https://www.dailystar.co.uk/sports/football/691672/premier-league-managers-bookies-favourites-2018-19-sacked-odds-sportsgallaries) (accessed 4.8.2018)
13. Joe Berstein, 'Rafa Benitez`s Huge 7m Settlement After Real Madrid Sacking Proves Why it can Pay not to Work as a Manager', Daily Mail Sports 5 January, 2016: (www.dailymail.co.uk/sport/football/article-3385439/Rafa-Benitez-huge-7m-settlement-Real-Madrid-prove-pay-Not-work-manager.htm;) (accessed 12.7.2018)
14. Emeka Nwani, 'How Austine Eguavoen`s Case has Exposed the Connivance of Nigerian Coaches to Play Fool', Goal.com, 19 March 2013: (www. Goal.com/en-ng/news/4082/comment/2013/03/19/3827/3827084/how -austin-egavoens-case-has-exposed-the-connivance-nigeria) (accessed 12.7.2018)
15. Cap. L1, LFN 2004.
16. Adeboye Amosu, '3SC Players Threaten Strike Over Unpaid Five Months Salaries', Complete Sports.com, 20 April 2016:(https://www.completesportsnigeria.com/3sc-players-threaten-strikes-unpaid-five-month-salaries ) (accessed 4.8.2018)
17. Nick Ames, 'Michael Uchebo: The Nigeria Striker Dying in Silence at Boavista', The Guardian.com, 30 November 2016:(https;//www.theguardian.com/football/2016/nov/30/Michael-uchebo-boavista-exile) (accessed 4.8.2018)
18. Xavi Hernandez, 'Barcelona Want to Avoid Paying 26m Euros to Neymar', Marca Sports, 31 July 2017: (www.marca.com/en/football/barcelona/2017/07/31/597f900d46163f410f8b46a6. html/) (accessed 12.7.18)
19. Tom Bunkham, 'How to Become a Football Agent', Reed.Co.UK, 16 January 2017: (https://www.reed.co.uk/carreer-advice/how-to-become-a-football-agent/ )(accessed 17.9.2018)
20. If terms negotiated by the appointed agent are later found to be suboptimal, compared to the player's prospective growth trajectory such could lead to problems. The same applies to conflicts interest or breach of agent's fiduciary duty to the player. For instance, Wilfried Bony (an Ivorian football player) reportedly claimed that two former football agents (Gilbert Kacou and Czech Dalibor Lacina) who had represented him received impermissible 'under-the-table cash' between 2013 and 2015. He consequently brought an action for recovery of more than £8m, against them. The court refused the agents' application to transfer the dispute to arbitration at this stage, finding that none of the agreements between Bony and his agents and their business entities expressly included or referred to the FA Rules, nor was there a valid clause stating any dispute should go to arbitration (an arbitration clause): Tom Proctor, 'On-Loan Stoke Striker Sues Former Agent Over £8m Lost Earning', 90Mins.com, 15 December 2016:(http://www.90mins.com/posts/4273904-on-loan-stoke-striker-wilfried-bony-sues-former-agents-over-8m-lost-earnings/ )(accessed 12.9.2018)
21. 'http://blog.fieldoo.com/2012/09/agreement-football-player-agent/ (accessed 04.08.2018).
22. FIFA has enacted these regulations in accordance with Article 4 of the Regulations Governing the Application of the FIFA Statutes.
23. It goes without saying that the representative contract must be well drafted, and the footballer (who may not be commercially savvy), would need legal advice in this regard. Such clarity would obviate the prospect of future (expensive/distractive) disputes between the footballer and the agent. For example, if the agent does not wish to include a termination clause in his representation contract, the player should at least provide the required flexibility, which allows the player to terminate the contract at certain moments (e.g. after every transfer window).
24. Adewale Ajayi, ' Nembe City FC Grabs Multi-Million Dollars Aieto Deal', BSN Sports News, 17 April 2018: (https: bsnsports.com.ng/nembe-city-fc-grabs-multi-million-dollars-aieto-deal/) (accessed 12.7.2018)
25. Palco Hernadez, 'Real Madrid Agree Record Breaking Sponsorship Deal With Emirates', AS Sports news, 21 September ,2017: (http;//en.as.com/en/2017/09/21/football/1506006163-369823.html) (accessed 12.7.2018)
26. Fisayo Dairo, '7 Basic Facts About the LMC / NTA Deal', Acl Sports News, 13 September, 2017: (https://www. aclsporlts.com/npfl-7-basic-basic-facts-lmcnta-deal/) (accessed 12.7.2018)
27. David Conn, 'Sky and BT Sport Retain Grip on Premier League Rights but TV Frenzy Cools', The Guardian, 13 February 2018:(http://www.theguardian.com/football/2018/feb/13/sky-bt-sport-premier-league )(accessed 12.7.2018)
28. Rotimi Fosan, 'Amos Adamu`s Last Dance?', Vanguard, 26 October 2010: (https://www.vanguardngrr.com/2010/10.com/2010/10/amos-adamu-last-dance/ ) (accessed 5.8.2018)
29. Festus Abu , 'Eagles Assistant Coach in Bribery Scandal', The Punch, 25 July 2018: (https://punchng.com/eng/eagles-assistant-coach-caught-in-bribery-scandal/ ) (accessed 6.8.2018)
30. Festus Abu, 'NFF Must Explain What They Did With Government Funds-Ladipo Says Eagles Were Denied NFSC Support', The Punch, 30 June 2018:(http://punchng.com/nff-must-explain-what-theydid-with-govt-funds-ladipo-says-eagles-were-denied-nfsc-support) (accessed 12.8.2018)
31.Adekunle Salami, 'Lessons of FIFA'S Ban Escape', New Telegraph, 25 August 2018: (http://newtelegraphonline.com/2018/08/lessons-of-fifas-ban-escape)(accessed 15.8.2018)
32. NPFLR 2014
33. CAS 2007/A/1298
34. CAS 2008/A/1519
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