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International Standard for Code Compliance by Signatories
The World Anti-Doping Code International Standard for Code Compliance by
Signatories is a mandatory International Standard developed as part of the World
Anti-Doping Program. It was developed in consultation with Signatories, publicauthorities, and other relevant stakeholders.
The International Standard for Code Compliance by Signatories was first adopted
in 2017 and came into effect in April 2018. A revised version was approved by the
WADA Executive Committee at the World Conference on Doping in Sport in
Katowice on 7 November 2019 and came into effect on 1 January 2021.
The present version was approved by the WADA Executive Committee on 16
November 2023, while its Annex B was approved by the WADA Executive
Committee on 11 March 2024. This revised version is effective as of 1 April 2024.

Published by:World Anti-Doping Agency
Stock Exchange Tower
800 Place Victoria (Suite 1700)
PO Box 120
Montreal, Quebec
Canada H3E 0B4
www.wada-ama.org
Tel:+1 514 904 9232
Fax: +1 514 904 8650
E-mail: code@wada-ama,org

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TABLE OF CONTENTSPART ONE: INTRODUCTION, CODE PROVISIONS, INTERNATIONAL STANDARD .......................... 5
1.0

Introduction and Scope ................................................................................................................ 5

2.0

Relevant Code and International Standard for Laboratories Provisions .................................. 6

3.0

Definitions and Interpretation ...................................................................................................... 6
3.1

Defined terms from the Code that are used in the International Standard for CodeCompliance by Signatories .................................................................................................... 6

3.2

Defined terms from the International Standard for Education ............................................... 12

3.3

Defined term from the International Standard for Laboratories ............................................ 12

3.4

Defined term from the International Standard for the Protection of Privacy and Personal
Information .......................................................................................................................... 13

3.5

Defined terms from the International Standard for Testing and Investigations ...................... 13

3.6

Defined term from the International Standard for Therapeutic Use Exemptions ................... 14

3.7

Defined terms specific to the International Standard for Code Compliance by Signatories 14

3.8Interpretation ....................................................................................................................................... 15

PART TWO: STANDARDS FOR WADA’S MONITORING AND ENFORCEMENT OF CODE.............. 16
COMPLIANCE BY SIGNATORIES ....................................................................................................... 16
4.0

Objective ...................................................................................................................................... 16

5.0

Roles, Responsibilities, and Procedures of the Different Bodies Involved in WADA’s . 16

6.0

5.1

Operational Oversight of Code Compliance ......................................................................... 17

5.2

Independent Review and Recommendations....................................................................... 18

5.3

Independent Determination of Non-Compliance and Signatory Consequences ................... 19

5.4

The Principle of Last Resort ................................................................................................ 19

5.5

Reinstatement Procedures ............................................................................................................... 23

WADA’s Support for Signatories’ Efforts to Achieve/Maintain Code Compliance ................. 23
6.1

Objective ............................................................................................................................. 22

6.2

Operational and Technical Support ..................................................................................... 22

7.0 Monitoring Signatories’ Code Compliance Efforts
7.1

Objective ............................................................................................................................. 23

7.2

Prioritization Between Different Signatories ......................................................................... 25

7.3

Cooperation with Other Bodies ............................................................................................ 25

7.4

WADA’s Monitoring Tools .................................................................................................... 27

7.5

Code Compliance Questionnaires ....................................................................................... 28

7.6

Mandatory Information Requests ......................................................................................... 29

7.7

The Compliance Audit Program ........................................................................................... 29
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7.8

Program Area Monitoring..................................................................................................... 31

7.9

Special Provisions Applicable to Major Event Organizations ...................................................... 33

8.0 Giving Signatories the Opportunity to Correct Non-Conformities .......................................... 35

9.0

8.1

Objective ............................................................................................................................. 34

8.2

Corrective Action Reports and Corrective Action Plans ....................................................... 34

8.3

Final Opportunity to Correct before Referral to the CRC ...................................................... 36

8.4

Referral to the CRC ............................................................................................................. 36

8.5

Fast-Track Procedure .......................................................................................................... 37

8.6

Event of Force Majeure ....................................................................................................... 39

Confirming Non-Compliance and Imposing Signatory Consequences................................... 39
9.1

CRC Recommendation ........................................................................................................ 39

9.2

Consideration by WADA’s Executive Committee ................................................................. 39

9.3

Acceptance by the Signatory ............................................................................................... 42

9.4

Determination by CAS ......................................................................................................... 41

9.5

Recognition and Enforcement by Other Signatories ............................................................ 45

9.6

Disputes about Reinstatement......................................................................................................... 45

10.0 Determining Signatory Consequences ...................................................................................... 45
10.1 Potential Signatory Consequences...................................................................................... 45
10.2 Principles Relevant to the Determination of the Signatory Consequences to be Applied in a
Particular Case ............................................................................................................................ 44
11.0 Reinstatement ............................................................................................................................. 46
11.1 Objective ............................................................................................................................. 46
11.2 Reinstatement Conditions.................................................................................................... 49
11.3 The Reinstatement Process ............................................................................................................. 50
12.0 Transitional Provisions............................................................................................................... 48
12.1 Proceedings Pending as of 1 April 2024.................................................................................... 48
ANNEX A: CATEGORIES OF NON-COMPLIANCE ............................................................................ 50
ANNEX B: SIGNATORY CONSEQUENCES ....................................................................................... 55

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PART ONE: INTRODUCTION, CODE PROVISIONS, INTERNATIONAL STANDARD
PROVISIONS, AND DEFINITIONS
1.0

Introduction and Scope
The purpose of the International Standard for Code Compliance by Signatories is to set out therelevant framework and procedures for ensuring Code Compliance by Signatories.
Signatories to the World Anti-Doping Code (the Code) commit to comply with a number of legal,
technical, and operational requirements that are set out in the Code and the accompanying
International Standards. Such compliance is necessary to deliver harmonized, coordinated, andeffective Anti-Doping Programs at the international and national level, so that Athletes and otherstakeholders can experience doping-free competition on a level playing field wherever sport isplayed.
The Code makes WADA responsible for monitoring and enforcing compliance by Signatories with
the Code and the International Standards. The Code also requires Signatories to report on theircompliance to WADA. Under the Code, it is the CAS, not WADA, that is responsible for determining
non-compliance and imposing consequences on Signatories if they do not accept WADA’s
allegation of non-compliance and/or the Signatory Consequences proposed by WADA.
The International Standard for Code Compliance by Signatories sets out:•

the roles, responsibilities, and procedures of the different bodies involved in WADA’s
compliance monitoring function (Part Two, Article 5);•

the support and assistance that WADA will offer to Signatories in their efforts to comply with theCode and the International Standards (Part Two, Article 6);•

the means by which WADA will monitor compliance by Signatories with their obligations under
the Code and the International Standards (Part Two, Article 7);•

the opportunities and support that WADA will offer to Signatories to correct Non-Conformities
before any formal action is taken (Part Two, Article 8);•

if a Signatory fails to correct the Non-Conformities, the process to be followed to get CAS tohear and determine an allegation of non-compliance and to determine the Signatory
Consequences of such non-compliance. This process mirrors, insofar as is appropriate andpracticable, the process followed in determining Code non-compliance and the Consequencesof such non-compliance for Athletes and other Persons (Part Two, Articles 9 and 10; Annexes
A and B);•

the principles to be applied by CAS to determine the Signatory Consequences to be imposedin a particular case, depending on the facts and circumstances of that case (Part Two, Article
10; Annexes A and B);•

the procedures that WADA will follow to ensure that a Signatory that has been determined to
be non-compliant is Reinstated as quickly as possible once it has corrected that non-compliance(Part Two, Article 11); and•the transitional provisions applicable to proceedings pending as of 1 April 2024 (Part Two,
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Article 12).
The ultimate objective is to ensure that strong Code-compliant anti-doping rules and programs areapplied and enforced consistently and effectively across all sports and all countries, so that clean
Athletes can have confidence that there is fair competition on a level playing field, and publicconfidence in the integrity of sport can be maintained. However, the International Standard for CodeCompliance by Signatories is flexible enough to recognize certain priorities. In particular, it includes
specific provisions (including a special fast-track procedure) to enable WADA to take urgent andeffective action to address instances of deliberate and/or bad faith non-compliance with Critical
Code requirements. It also gives WADA discretion to prioritize its compliance efforts in particularareas and/or with particular Signatories. Most importantly, Signatories who are seeking in good faith
to comply with the Code will be encouraged and supported to achieve and maintain full CodeCompliance. The desire is always to have Signatories address any compliance issues voluntarily.
Having a Signatory declared non-compliant and Signatory Consequences imposed is the last resort,
to be pursued only where the Signatory has failed, despite every encouragement, to correct its NonConformities.
In the interests of transparency and accountability, WADA may publish as much detail as it
considers appropriate about its general compliance monitoring program. It may also publish
information about activities and outcomes in respect of individual Signatories who have been thesubject of specific action under the program.
Terms used in this International Standard that are defined terms from the Code are italicized. Terms
that are defined in this or another International Standard are underlined.
2.0

Relevant Code and International Standard for Laboratories Provisions
The following articles in the Code are directly relevant to the International Standard for CodeCompliance by Signatories. They can be obtained by referring to the Code itself:•

Article 12 Sanctions by Signatories Against Other Sporting Bodies•

Article 13.6 Appeals from Decisions under Article 24.1•

Article 20 Additional Roles and Responsibilities of Signatories and WADA•

Article 24 Monitoring and Enforcing Compliance with the Code and UNESCO Convention.

The following articles in the International Standard for Laboratories are directly relevant to theInternational Standard for Code Compliance by Signatories. They can be obtained by referring to
the International Standard for Laboratories itself:

3.0•

Article 4.1.2 Applicant Laboratory, Submit Initial Application Form•

Article 4.7.1 Applicant Laboratory for WADA approval for the ABP, Submit Initial Application
Form.

Definitions and Interpretation
3.1

Defined terms from the Code that are used in the International Standard for CodeCompliance by Signatories
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ADAMS: The Anti-Doping Administration and Management System is a Web-based databasemanagement tool for data entry, storage, sharing, and reporting designed to assist
stakeholders and WADA in their anti-doping operations in conjunction with data protection
legislation.
Adverse Analytical Finding: A report from a WADA-accredited laboratory or other WADAapproved laboratory that, consistent with the International Standard for Laboratories,
establishes in a Sample the presence of a Prohibited Substance or its Metabolites or Markers
or evidence of the Use of a Prohibited Method.
Adverse Passport Finding: A report identified as an Adverse Passport Finding as describedin the applicable International Standards.
Aggravating Factors: This term encompasses a deliberate attempt to circumvent or
undermine the Code or the International Standards and/or to corrupt the anti-doping system,
an attempt to cover up non-compliance, or any other form of bad faith on the part of the
Signatory in question; a persistent refusal or failure by the Signatory to make any reasonable
effort to correct Non-Conformities that are notified to it by WADA; repeat offending; and anyother factor that aggravates the Signatory’s non-compliance.
Anti-Doping Activities: Anti-doping Education and information, test distribution planning,
maintenance of a Registered Testing Pool, managing Athlete Biological Passports,
conducting Testing, organizing analysis of Samples, gathering of intelligence and conduct ofinvestigations, processing of TUE applications, Results Management, hearings, monitoringand enforcing compliance with any Consequences imposed, and all other activities related toanti-doping to be carried out by or on behalf of an Anti-Doping Organization, as set out in the
Code and/or the International Standards.
Anti-Doping Organization: WADA or a Signatory that is responsible for adopting rules for
initiating, implementing or enforcing any part of the Doping Control process. This includes, forexample, the International Olympic Committee, the International Paralympic Committee, other
Major Event Organizations that conduct Testing at their Events, International Federations,and National Anti-Doping Organizations.
Approved Third Party: One or more Anti-Doping Organizations and/or Delegated Third
Parties selected or approved by WADA, following consultation with the non-compliant
Signatory, to Supervise or Takeover some or all of that Signatory’s Anti-Doping Activities. As
a last resort, if there is no other suitable body available, then WADA may carry out this function
itself.
Athlete: Any Person who competes in sport at the international level (as defined by each
International Federation) or the national level (as defined by each National Anti-Doping
Organization). An Anti-Doping Organization has discretion to apply anti-doping rules to an
Athlete who is neither an International-Level Athlete nor a National-Level Athlete, and thus tobring them within the definition of “Athlete.” […][Comment to Athlete: Individuals who participate in sport may fall in one of five categories: 1)
International-Level Athlete, 2) National-Level Athlete, 3) individuals who are not International- or
National-Level Athletes but over whom the International Federation or National Anti-Doping
Organization has chosen to exercise authority, 4) Recreational Athlete, and 5) individuals over whom
no International Federation or National Anti-Doping Organization has, or has chosen to, exercise
authority. All International- or National-Level Athletes are subject to the anti-doping rules of the Code,

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with the precise definitions of international and national level sport to be set forth in the anti-doping
rules of the International Federations and National Anti- Doping Organizations.]

Athlete Biological Passport: The program and methods of gathering and collating data as
described in the International Standard for Testing and Investigations and International
Standard for Laboratories.
Athlete Support Personnel: Any coach, trainer, manager, agent, team staff, official, medical,
paramedical personnel, parent or any other Person working with, treating or assisting an
Athlete participating in or preparing for sports Competition.
Atypical Finding: A report from a WADA-accredited laboratory or other WADA-approved
laboratory which requires further investigation as provided by the International Standard forLaboratories or related Technical Documents prior to the determination of an Adverse
Analytical Finding.
CAS: The Court of Arbitration for Sport.
Code: The World Anti-Doping Code.
Consequences of Anti-Doping Rule Violations (“Consequences”): An Athlete’s or other
Person’s violation of an anti-doping rule may result in one or more of the following: (a)Disqualification means the Athlete’s results in a particular Competition or Event areinvalidated, with all resulting Consequences including forfeiture of any medals, points andprizes; (b) Ineligibility means the Athlete or other Person is barred on account of an antidoping rule violation for a specified period of time from participating in any Competition orother activity or funding as provided in Article 10.14.1; (c) Provisional Suspension means the
Athlete or other Person is barred temporarily from participating in any Competition or activity
prior to the final decision at a hearing conducted under Article 8; (d) Financial Consequencesmeans a financial sanction imposed for an anti-doping rule violation or to recover costs
associated with an anti-doping rule violation; and (e) Public Disclosure means thedissemination or distribution of information to the general public or Persons beyond those
Persons entitled to earlier notification in accordance with Article 14. Teams in Team Sports
may also be subject to Consequences as provided in Article 11.
Critical: A requirement that is considered to be Critical to the fight against doping in sport.
See further Annex A of the International Standard for Code Compliance by Signatories.
Delegated Third Party: Any Person to which an Anti-Doping Organization delegates any
aspect of Doping Control or anti-doping Education programs including, but not limited to, third
parties or other Anti-Doping Organizations that conduct Sample collection or other Doping
Control services or anti-doping Educational programs for the Anti-Doping Organization, or
individuals serving as independent contractors who perform Doping Control services for the
Anti-Doping Organization (e.g., non-employee Doping Control officers or chaperones). Thisdefinition does not include CAS.
Doping Control: All steps and processes from test distribution planning through to ultimate
disposition of any appeal and the enforcement of Consequences, including all steps andprocesses in between, including but not limited to, Testing, investigations, whereabouts,
TUEs, Sample collection and handling, laboratory analysis, Results Management, hearings
and appeals, and investigations or proceedings relating to violations of Article 10.14 (Status
During Ineligibility or Provisional Suspension).
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Education: The process of learning to instill values and develop behaviors that foster andprotect the spirit of sport, and to prevent intentional and unintentional doping.
Event: A series of individual Competitions conducted together under one ruling body (e.g.,the Olympic Games, world championships of an International Federation, or Pan American
Games). 1
Fine: Payment by the Signatory of an amount that reflects the seriousness of the noncompliance/Aggravating Factors, its duration, and the need to deter similar conduct in the
future. In a case that does not involve non-compliance with any Critical requirements, the Fineshall not exceed the lower of (a) 10% of the Signatory’s total annual budgeted expenditure;and (b) US$100,000. The Fine will be applied by WADA to finance further Code compliancemonitoring activities and/or anti-doping Education and/or anti-doping research.
General: A requirement that is considered to be important to the fight against doping in sport
but does not fall into the categories of Critical or High Priority. See further Annex A of theInternational Standard for Code Compliance by Signatories.
High Priority: A requirement that is considered to be High Priority but not Critical in the fightagainst doping in sport. See further Annex A of the International Standard for CodeCompliance by Signatories.
Independent Observer Program: A team of observers and/or auditors, under thesupervision of WADA, who observe and provide guidance on the Doping Control process prior
to or during certain Events and report on their observations as part of WADA’s compliancemonitoring program.
International Event: An Event or Competition where the International Olympic Committee,
the International Paralympic Committee, an International Federation, a Major Event
Organization, or another international sport organization is the ruling body for the Event or
appoints the technical officials for the Event.
International Standard: A standard adopted by WADA in support of the Code. Compliancewith an International Standard (as opposed to another alternative standard, practice orprocedure) shall be sufficient to conclude that the procedures addressed by the International
Standard were performed properly. International Standards shall include any TechnicalDocuments issued pursuant to the International Standard.
Major Event Organizations: The continental associations of National Olympic Committees
and other international multi-sport organizations that function as the ruling body for any
continental, regional or other International Event.
National Anti-Doping Organization: The entity(ies) designated by each country as
possessing the primary authority and responsibility to adopt and implement anti-doping rules,
direct the collection of Samples, manage test results and conduct Results Management at thenational level. If this designation has not been made by the competent public authority(ies),
Where the term ‘Event’ is used in Annex B of this International Standard for Code Compliance by Signatories,
it has the meaning set out above, but in addition the event must be under the authority of a Signatory in order to qualify
as an ‘Event’ for purposes of Annex B.

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the entity shall be the country’s National Olympic Committee or its designee.
National Olympic Committee: The organization recognized by the International Olympic
Committee. The term National Olympic Committee shall also include the National Sport
Confederation in those countries where the National Sport Confederation assumes typical
National Olympic Committee responsibilities in the anti-doping area.
Non-Conformity: Where a Signatory is not complying with the Code and/or one or moreInternational Standards and/or any requirements imposed by the WADA Executive
Committee, but the opportunities provided in the International Standard for Code Complianceby Signatories to correct the Non-Conformity/Non-Conformities have not yet expired and so
WADA has not yet formally alleged that the Signatory is non-compliant.
Person: A natural Person or an organization or other entity.
Publicly Disclose: See Consequences of Anti-Doping Rule Violations above.
Registered Testing Pool: The pool of highest-priority Athletes established separately at theinternational level by International Federations and at the national level by National AntiDoping Organizations, who are subject to focused In-Competition and Out-of-Competition
Testing as part of that International Federation’s or National Anti-Doping Organization’s test
distribution plan and therefore are required to provide whereabouts information as provided
in Article 5.5 and the International Standard for Testing and Investigations.
Reinstatement: When a Signatory that was previously declared non-compliant with the Codeand/or the International Standards is determined to have corrected that non-compliance andto have met all of the other conditions imposed in accordance with Article 11 of theInternational Standard for Code Compliance by Signatories for Reinstatement of its name tothe list of Code-compliant Signatories (and Reinstated shall be interpreted accordingly).
Representatives: Officials, directors, officers, elected members, employees, and committee
members of the Signatory or other body in question, and also (in the case of a National AntiDoping Organization or a National Olympic Committee acting as a National Anti-Doping
Organization) Representatives of the government of the country of that National Anti-Doping
Organization or National Olympic Committee.
Results Management: The process encompassing the timeframe between notification as per
Article 5 of the International Standard for Results Management, or in certain cases (e.g.,
Atypical Finding, Athlete Biological Passport, Whereabouts Failure), such pre-notification
steps expressly provided for in Article 5 of the International Standard for Results
Management, through the charge until the final resolution of the matter, including the end of
the hearing process at first instance or on appeal (if an appeal was lodged).
Sample or Specimen: Any biological material collected for the purposes of Doping Control.
[Comment to Sample or Specimen: It has sometimes been claimed that the collection of blood
Samples violates the tenets of certain religious or cultural groups. It has been determined that
there is no basis for any such claim.]
Signatories: Those entities accepting the Code and agreeing to implement the Code, as

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provided in Article 23. 2
Special Monitoring: Where, as part of the consequences imposed on a non-compliant
Signatory, WADA applies a system of specific and ongoing monitoring to some or all of the
Signatory’s Anti-Doping Activities, to ensure that the Signatory is carrying out those activities
in a compliant manner.
Supervision: Where, as part of the consequences imposed on a non-compliant Signatory,
an Approved Third Party oversees and supervises the Signatory’s Anti-Doping Activities, as
directed by WADA, at the Signatory’s expense (and Supervise shall be interpreted
accordingly). Where a Signatory has been declared non-compliant and has not yet finalizeda Supervision agreement with the Approved Third Party, that Signatory shall not implement
independently any Anti-Doping Activity in the area(s) that the Approved Third Party is tooversee and supervise without the express prior written agreement of WADA.
Takeover: Where, as part of the consequences imposed on a non-compliant Signatory, anApproved Third Party takes over all or some of the Signatory's Anti-Doping Activities, as
directed by WADA, at the Signatory’s expense. Where a Signatory has been declared noncompliant and has not yet finalized a Takeover agreement with the Approved Third Party, that
Signatory shall not implement independently any Anti-Doping Activity in the area(s) that the
Approved Third Party is to take over without the express prior written agreement of WADA.
Target Testing: Selection of specific Athletes for Testing based on criteria set forth in theInternational Standard for Testing and Investigations.
Technical Document: A document adopted and published by WADA from time to time
containing mandatory technical requirements on specific anti-doping topics as set forth in an
International Standard.
Testing: The parts of the Doping Control process involving test distribution planning, Sample
collection, Sample handling, and Sample transport to the laboratory.
Therapeutic Use Exemption (TUE): A Therapeutic Use Exemption allows an Athlete with a
medical condition to use a Prohibited Substance or Prohibited Method, but only if theconditions set out in Article 4.4 and the International Standard for Therapeutic Use
For purposes of this International Standard for Code Compliance by Signatories, if a Signatory is replaced bya successor entity, then (unless WADA decides otherwise) the successor entity will be deemed, by virtue of its
acceptance of the role of successor to or replacement for that Signatory under and in accordance with the Code: (1)to have acquired the rights of the predecessor Signatory to dispute any compliance issue; and (2) to have assumed
the liability of the predecessor Signatory for any compliance issue (including being bound by any resulting
Consequences and having to satisfy any resulting Reinstatement conditions). For these purposes, a ‘compliance issue’means any non-compliance that took place before the time of replacement but for which a compliance procedure: (a)has not yet been started at the time of the replacement; or (b) has been started by the time of the replacement but not
yet completed (i.e., the asserted non-compliance has not yet been determined and/or the Consequences imposed on
account of the non-compliance have not yet been discharged in full and/or the Reinstatement conditions imposed have
not yet been satisfied in full). Where a Signatory is to be replaced by more than one successor entity, either agreement
shall be reached with WADA that one of the successor entities will acquire the rights and assume the liability of thepredecessor Signatory in respect of any compliance issue, or else each of the successor entities will be deemed, by
virtue of its acceptance of the role of partial successor to or replacement for that Signatory under and in accordancewith the Code, to have acquired such rights and assumed such liability on a joint and several basis with the othersuccessor entity/ies.
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Exemptions are met.
UNESCO Convention: The International Convention against Doping in Sport adopted by the33rd session of the UNESCO General Conference on 19 October 2005, including any and allamendments adopted by the States Parties to the Convention and the Conference of Parties
to the International Convention against Doping in Sport.
WADA: The World Anti-Doping Agency.
3.2

Defined terms from the International Standard for Education
Education Plan: A document that includes: a situation assessment; identification of an
Education Pool; objectives; Education activities and monitoring procedures as required by
Article 4.
Education Pool: A list of target groups identified through a system assessment process.
Education Program: A collection of Education activities undertaken by a Signatory to achieve
the intended learning objectives.
Educator: A person who has been trained to deliver Education and is authorized by a Signatory
for this purpose.
Values-Based Education: Delivering activities that emphasize the development of anindividual’s personal values and principles, to build their capacity to make decisions to behave
ethically.

3.3

Defined term from the International Standard for Laboratories
Athlete Passport Management Unit (APMU): A unit composed of a Person or Persons thatis responsible for the timely management of Athlete Biological Passports in ADAMS on behalfof the Passport Custodian.

3.4

Defined term from the International Standard for the Protection of Privacy andPersonal Information
Personal Information: Information, including without limitation Sensitive Personal
Information, relating to an identified or identifiable Participant or other Person whose
information is Processed solely in the context of an Anti-Doping Organization’s Anti-Doping
Activities.
[Comment to Personal Information: It is understood that Personal Information includes, but is not limited
to, information relating to an Athlete’s name, date of birth, contact details and sporting affiliations,whereabouts, designated TUEs (if any), anti-doping test results, and Results Management (including
disciplinary hearings, appeals and sanctions). Personal Information also includes personal details andcontact information relating to other Persons, such as medical professionals and other Persons working
with, treating or assisting an Athlete in the context of Anti-Doping Activities. Such information remains
Personal Information and is regulated by this International Standard for the entire duration of its
Processing, irrespective of whether the relevant individual remains involved in organized sport.]

3.5

Defined terms from the International Standard for Testing and Investigations
Chain of Custody: The sequence of individuals or organizations who have responsibility forPage 12 of 62

the custody of a Sample from the provision of the Sample until the Sample has been delivered
to the laboratory for analysis.
No Advance Notice Testing: Sample collection that takes place with no advance warning to
the Athlete and where the Athlete is continuously chaperoned from the moment of notification
through Sample provision.
Risk Assessment: The assessment of risk of doping in a sport or sports discipline conductedby an Anti-Doping Organization in accordance with Article 4.2.
Sample Collection Authority: The organization that is responsible for the collection of
Samples in compliance with the requirements of the International Standard for Testing andInvestigations, whether (1) the Testing Authority itself; or (2) a Delegated Third Party to whom
the authority to conduct Testing has been granted or sub-contracted. The Testing Authority
always remains ultimately responsible under the Code for compliance with the requirementsof the International Standard for Testing and Investigations relating to collection of Samples.
Sample Collection Equipment: A and B bottles, kits or containers, collection vessels, tubes
or other apparatus used to collect, hold or store the Sample at any time during and after the
Sample Collection Session that shall meet the requirements of Article 6.3.4.
Sample Collection Personnel: A collective term for qualified officials authorized by the
Sample Collection Authority to carry out or assist with duties during the Sample Collection
Session.
Sample Collection Session: All of the sequential activities that directly involve the Athlete
from the point that initial contact is made until the Athlete leaves the Doping Control Station
after having provided their Sample(s).
Test Distribution Plan: A document written by an Anti-Doping Organization that plans
Testing on Athletes over whom it has Testing Authority, in accordance with the requirementsof Article 4.
3.6

Defined term from the International Standard for Therapeutic Use Exemptions
Therapeutic Use Exemption Committee (or “TUEC”): The panel established by an AntiDoping Organization to consider applications for TUEs.

3.7

Defined terms specific to the International Standard for Code Compliance by
Signatories
Anti-Doping Program: The legislation, rules, regulations, processes and procedures, andother activities (including Anti-Doping Activities) that a Signatory is required to implement inorder to achieve Code Compliance.
Code Compliance: Compliance with all of the requirements in the Code and/or theInternational Standards that apply to the Signatory in question, as well as with any special
requirements imposed by the WADA Executive Committee.
Code Compliance Questionnaire: A self-assessment survey issued by WADA in the formof a questionnaire, which a Signatory uses to report to WADA on the Signatory’s CodeCompliance.
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Compliance Audit: A formal assessment conducted by WADA of all or part of a Signatory’s
Anti-Doping Program, in accordance with Article 7.7.
Compliance Review Committee or CRC: As described in Article 5.2.1.
Corrective Action Plan: A plan drafted by a Signatory, setting out how the Signatory will
implement the corrective actions identified by WADA in a Corrective Action Report within thetimeframes set in that report.
Corrective Action Report: A report produced by WADA that identifies Non-Conformities bya Signatory, the actions that the Signatory must take to correct them, and the timeframes
within which those corrective actions must be completed.
Event of Force Majeure: An event affecting a Signatory’s ability to achieve full CodeCompliance that arises from or is attributable to acts, events, omissions, or accidents that are
beyond the reasonable control of the Signatory. Such events may include any natural physicaldisaster, war, military operations, riot, crowd disorder, strike, lock-outs or other industrial action,
terrorist action, or civil commotion. In no circumstances, however, shall it be considered an
Event of Force Majeure (whether to excuse Non-Conformities, or to mitigate the Consequences
to be imposed for Non-Conformities, or to excuse non-satisfaction of any Reinstatement
conditions):(1) that the Non-Conformity has been caused by a lack of resources, changes in elected
officials or personnel, or by any act or omission (including any interference and/or afailure to provide support) by any governmental or other public authorities. Each
Signatory has voluntarily accepted the obligation to comply with its obligations under the
Code and the International Standards, which includes an obligation under Code Article
23.3 to devote sufficient resources, and (where applicable) an obligation to secure thesupport of governmental and other public authorities, as required in order to achieve andmaintain Code Compliance; or(2) that the Signatory delegated the task of complying with some or all of its obligations under
the Code and/or the International Standards to a Delegated Third Party (such as aSample Collection Authority to whom the Signatory has assigned the task of collecting
Samples; or a local organizing committee to which a Major Event Organization has
assigned the task of running its Anti-Doping Program at the Event in question).
[Comment to Event of Force Majeure: As CAS ruled in RPC v IPC, CAS 2016/A/4745, (a) a body withan obligation to enforce the Code within its sphere of authority remains fully liable for any violations
even if they are due to the actions of other bodies that it relies on but that it does not control; and (b)just as an Athlete cannot escape the Consequences of an anti-doping rule violation by delegating his
or her responsibility to comply with his or her anti-doping obligations to others, so too a Signatory has
an absolute and non-delegable obligation to comply with the requirements of the Code and theInternational Standards. The Signatory has the right to decide how to meet that obligation, including
the right to assign certain tasks to appropriate third parties, should it see fit, but it remains fully
responsible for complying with the Code and the International Standards, and is fully liable for any noncompliance caused by any failures of such third party.]

Mandatory Information Request: A request that WADA may send to a Signatory, requiring
the Signatory to provide specified information by a specified date to enable WADA to assess
the Signatory’s Code Compliance.
Prioritization Policy: A policy proposed by WADA Management and approved by the CRC
to prioritize the monitoring for Code Compliance of certain categories of Signatories and/or
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the enforcement of certain requirements, as further described in Article 7.2.
Signatory Consequences: One or more of the consequences set out in Code Article 24.1.12
that may be imposed on a Signatory as a result of its failure to maintain Code Compliance,such consequences to be based on the particular facts and circumstances of the case athand, and applying the principles set out in Article 10.
WADA Auditor: A suitably experienced WADA staff member or external anti-doping
specialist who has been trained by WADA to conduct the assessment of a Signatory’s CodeCompliance. The WADA Auditor should be free of any conflict of interest in respect of each
Compliance Audit that he/she undertakes.
WADA Privileges: The benefits listed at Code Article 24.1.12.1.
Watchlist Procedure: The special procedure described in Article 8.4.5.
3.8

Interpretation
3.8.1

The official text of the International Standard for Code Compliance by Signatories shallbe maintained by WADA and shall be published in English and French. In the eventof any conflict between the English and French versions, the English version shallprevail.

3.8.2

Like the Code, the International Standard for Code Compliance by Signatories has
been drafted giving consideration to the principles of proportionality, human rights,
and other applicable legal principles. It shall be interpreted and applied in that light.

3.8.3

The comments annotating various provisions of the International Standard for CodeCompliance by Signatories shall be used to guide its interpretation.

3.8.4

Unless otherwise specified, references to Articles or Annexes are references to
Articles or Annexes of the International Standard for Code Compliance by Signatories.

3.8.5

Where the term “days” is used in the International Standard for Code Compliance by
Signatories, it shall mean calendar days unless otherwise specified.

3.8.6

The Annexes to the International Standard for Code Compliance by Signatories havethe same mandatory status as the rest of the International Standard.

Page 15 of 62

PART TWO: STANDARDS FOR WADA’S MONITORING AND ENFORCEMENT OF CODECOMPLIANCE BY SIGNATORIES
4.0

5.0

Objective
4.1

The objective of Part Two of the International Standard for Code Compliance by Signatories
is to ensure that Signatories deliver Anti-Doping Programs within their respective spheres of
responsibility that meet the requirements of the Code and the International Standards, so that
there is a level playing field wherever sport is played.

4.2

The desire is always to have Signatories address any compliance issues voluntarily. Having
a Signatory declared non-compliant and Signatory Consequences imposed is the last resort,
to be pursued only where the Signatory has failed, despite every encouragement, to take thenecessary corrective actions within the required timeframes.

4.3

Therefore, the focus of WADA’s compliance monitoring program is on dialogue andcommunication with Signatories, assisting them in their efforts to ensure full CodeCompliance, and providing them with guidance for the continuous improvement of their AntiDoping Programs. Where instances of Non-Conformity are identified, the International
Standard for Code Compliance by Signatories establishes objective, pre-determined, andtransparent procedures and standards that give the Signatory the opportunity to correct those
Non-Conformities, and that lead (if the Non-Conformities are not corrected) to a determinationof non-compliance and the imposition of predictable, graded, and proportionate Signatory
Consequences. The International Standard for Code Compliance by Signatories also sets out
a clear pathway to Reinstatement.

Roles, Responsibilities, and Procedures of the Different Bodies Involved in WADA’s
Compliance Monitoring Function

Page 16 of 62

Figure One: Flow chart depicting the process from the identification of Non-Conformity to an allegation of noncompliance (Articles 5.1 to 5.3) 3

5.1

Operational Oversight of Code Compliance5.1.1

Operational oversight of Code Compliance is provided by WADA Management throughan internal WADA Compliance Taskforce consisting of staff from different WADA

Note: The diagram does not depict a compliance procedure where there is no Corrective Action Report, i.e.,a compliance procedure triggered by a failure to respond to a Code Compliance Questionnaire or a Mandatory
Information Request or a compliance procedure conducted on a fast-track basis further to Article 8.5.
3Page 17 of 62

departments.
5.1.2

5.2

WADA Management is responsible for coordinating and directing the development of
all activities related to WADA’s compliance monitoring program in coordination with
the Compliance Review Committee (CRC), and in accordance with any prioritizationof effort approved by the CRC further to Article 7.2. This includes:
5.1.2.1

coordinating the provision of ongoing support and assistance by WADA to
Signatories in meeting their obligations under the Code and the International
Standards (see Article 6);

5.1.2.2

using all tools at WADA’s disposal to monitor Code Compliance by
Signatories, including but not limited to ADAMS, Code Compliance
Questionnaires, Mandatory Information Requests, Compliance Audits,
information obtained by program area monitoring, and any other relevant
information received or collected by WADA (see Article 7);

5.1.2.3

where Non-Conformities are identified, opening a dialogue with the
Signatory, identifying corrective actions to be taken by the Signatory tocorrect the Non-Conformities, and providing guidance to help the Signatory
to complete the corrective actions within the set timeframes (see Article 8);

5.1.2.4

assessing whether the Signatory’s corrective actions have corrected theNon-Conformities in full, referring cases to the CRC where the NonConformities have not been corrected in full, providing reports with relevant
supporting information and any observations that WADA Management
considers appropriate and/or that are requested by the CRC in order tofacilitate CRC discussions, and implementing and following up on CRC
recommendations (see Articles 8 and 9);

5.1.2.5

where a Signatory fails to correct the Non-Conformities within the required
timeframe, and following the recommendation of the CRC, obtaining theapproval of WADA's Executive Committee to notify the Signatory formally of
the alleged non-compliance, with such notice also specifying the Signatory
Consequences that it is contended should apply for such non-complianceand the conditions that it is proposed the Signatory should have to satisfy inorder to be Reinstated (see Articles 8, 9, 10 and 11); and5.1.2.6

monitoring the Signatory’s efforts to satisfy the Reinstatement conditions
imposed on it, in order to report to the CRC on whether and when to
recommend that the Signatory be Reinstated (see Article 11).

Independent Review and Recommendations
5.2.1

The Compliance Review Committee is an independent, non-political WADA Special
Committee thatoversees WADA’s Code Compliance monitoring efforts andenforcement activities, and provides advice and recommendations on such matters to
WADA’s Executive Committee.
5.2.1.1

The CRC is governed by Terms of Reference that are designed to ensure
the independence, political neutrality, and specialization of its members, andthat underpin the credibility of its work. The Terms of Reference include strict
Page 18 of 62

conflict of interest provisions that require CRC members to declare any
potential conflicts of interest and to exclude themselves from all CRC
deliberations in any matter in which they have a conflict of interest.
5.2.2

5.2.3

5.3

5.4

The CRC follows standardized procedures encompassing review, assessment,
communication, and the making of recommendations to WADA’s Executive Committee
on matters relating to Code Compliance, correction of Non-Conformities, andReinstatement. These procedures (see Articles 8, 9 and 11) are designed to support
a transparent, objective, and consistent approach to the assessment and enforcementof Code Compliance.
5.2.2.1

Where WADA Management reports apparent Non-Conformities to the CRC,
a procedure is followed that gives the Signatory in question the time andopportunity to explain and correct the Non-Conformities within a specified
timeframe as to achieve full Code Compliance (see Article 8).

5.2.2.2

If the Signatory does not correct the Non-Conformities within the frameworkof that procedure, the CRC will review the case in detail and decide whether
to recommend to WADA’s Executive Committee that a formal notice beissued to the Signatory alleging non-compliance (see Article 5.3).

In addition to reviewing and assessing compliance-related issues raised by WADA
Management, at any time the CRC may identify compliance-related issues of its own
accord to be addressed by WADA Management.

Independent Determination of Non-Compliance and Signatory Consequences
5.3.1

In accordance with Code Article 24.1.4, upon the recommendation of the CRC,
WADA’s Executive Committee may approve the sending to a Signatory of a formal
notice of its alleged non-compliance with the Code and/or the International Standards,
with such notice also specifying the Signatory Consequences that it is contended
should apply for such non-compliance, and the conditions that it is proposed the
Signatory should have to satisfy in order to be Reinstated.

5.3.2

In accordance with Code Article 24.1.5, if the Signatory accepts or does not disputethe contents of that notice within twenty-one (21) days of its receipt, the allegation of
non-compliance will be deemed admitted and the Signatory Consequences andReinstatement conditions will be deemed accepted, and (subject to Article 9.3) thenotice will automatically become a final decision enforceable with immediate effect inaccordance with Code Article 24.1.9. If the Signatory disputes any part of the notice,
the dispute will be resolved by CAS in accordance with Code Article 24.1.6.

5.3.3

Once the notice is accepted as a final decision by the Signatory, or (if disputed) oncea final decision is issued by CAS, then (in accordance with Code Article 24.1.9) thatdecision shall be applicable worldwide and shall be recognized, respected and given
full effect by all other Signatories in accordance with their authority and within theirrespective spheres of responsibility (see Figure Two below).

The Principle of Last Resort
5.4.1

Consistent with the principle of ‘last resort’, in any case (including not only ordinary but
Page 19 of 62

also fast track cases), if a Signatory does not meet the required timeframes forcorrecting Non-Conformities and so the case is referred to the CRC and beyond, if the
Signatory corrects the Non-Conformities at any time before Signatory Consequences
are imposed by CAS then no Signatory Consequences shall be imposed, save to theextent that (a) costs have been incurred in pursuing the case before CAS (in whichcase the Signatory must cover those costs); and/or (b) the failure to correct a NonConformity within the required timeframe has resulted in irreparable prejudice to thefight against doping in sport (in which case Signatory Consequences may be imposed
to reflect that prejudice).

Page 20 of 62

Figure Two: Flow chart depicting the process following a formal allegation of non-compliance (Articles 5.3.1, 5.3.2
and 5.3.3)

5.5

Reinstatement Procedures
5.5.1

Where applicable, WADA Management will report to the CRC on the Signatory’s
implementation of the Reinstatement conditions, and the CRC will then makerecommendations to WADA’s Executive Committee as to whether or not the Signatory
Page 21 of 62

has satisfied those conditions and should be Reinstated.
5.5.2

6.0

Where WADA’s Executive Committee alleges that a Signatory has not yet satisfied its
Reinstatement conditions and so should not yet be Reinstated, if the Signatory
disputes that allegation, the dispute will be resolved by CAS in accordance with Code
Article 24.1.10. In accordance with Code Article 24.1.9, the CAS decision shall beapplicable worldwide and shall be recognized, respected and given full effect by allother Signatories in accordance with their authority and within their respective spheresof responsibility.

WADA’s Support for Signatories’ Efforts to Achieve/Maintain Code Compliance6.1

Objective
6.1.1

6.2

WADA’s priority is to support Signatories in strengthening their Anti-Doping Programs,
thereby increasing the protection that they provide to clean Athletes. It shall remain at
all times the Signatory’s obligation to achieve full Code Compliance, and it shall not be
a defense or excuse that others did not help the Signatory to comply. However, WADA
will use all reasonable endeavors to provide support and assistance to Signatories
seeking to achieve, maintain or return to full Code Compliance.

Operational and Technical Support
6.2.1

WADA will provide operational and technical support to Signatories to assist them toachieve, maintain, or (where applicable) return to full Code Compliance, including by
providing advice and information, by developing resources, guidelines, training
materials, and training programs, and by facilitating partnerships with other AntiDoping Organizations where possible. Where the WADA budget allows, this support
shall be provided without cost to Signatories.

6.2.2

WADA will maintain a number of documents and tools to assist Signatories tounderstand their responsibilities under the Code and the International Standards, andto achieve and maintain full compliance with those responsibilities, including:

6.2.3

6.2.2.1

model rules for the implementation of the Code and the International
Standards within the Signatory’s area of competence;

6.2.2.2

guideline documents covering the implementation of various components ofa Code-compliant Anti-Doping Program, including (without limitation)
Testing, TUEs, Results Management, Education, and intelligence andinvestigations;

6.2.2.3

template documents and forms; and6.2.2.4

online Education tools.

WADA also maintains the Code Compliance Questionnaire and the Compliance Audit
program, which are designed to help Signatories to identify Non-Conformities in their
Anti-Doping Programs and to devise and implement plans to correct those NonConformities. WADA will provide various forms of support and assistance toSignatories in understanding the Code Compliance Questionnaire, the Compliance
Audit program, and all other aspects of the compliance monitoring program, including
Page 22 of 62

information sessions; a dedicated section of its website where materials relevant tothe compliance monitoring program are posted, including answers to Frequently Asked
Questions; and other support resources.

7.0

6.2.4

A Signatory may seek assistance from another Signatory to help it achieve full CodeCompliance (and WADA will support Signatories in setting up such partnerships,
including providing on its website further information and guidelines on partnershipagreements) and/or the Signatory may appoint a Delegated Third Party to carry out
Anti- Doping Activities on its behalf. In accordance with Code Article 20 and Article
8.4.3 of this International Standard for Code Compliance by Signatories, however, theSignatory shall always remain fully liable for any Non-Conformities arising as a result.
The Signatory shall ensure that it is able to require the Delegated Third Party tocooperate in full with (and to enable the Signatory to cooperate in full with) all of
WADA’s compliance monitoring efforts, including (without limitation) properly
addressing Code Compliance Questionnaires, Mandatory Information Requests,
Compliance Audits, and all program area monitoring requirements further to Article
7.8.

6.2.5

As set out in Article 8, when Non-Conformities are identified, whether in a completed
Code Compliance Questionnaire or in a Compliance Audit or otherwise, the focus of
WADA Management will be on assisting the Signatory in question through dialogue
and support to achieve full Code Compliance. The Signatory will be given an adequate
opportunity to dispute or to correct the Non-Conformities, including (if necessary) by
WADA providing a Corrective Action Report that sets out which corrective actions are
required, and specifies the timeframes for their completion. The Corrective Action
Report may also include recommendations as to best practice, and may refer, whereappropriate, to resources and materials posted on WADA’s website that may assist
the Signatory in responding to the report and strengthening its Anti-Doping Program.
In addition, WADA will review any Corrective Action Plan (including any requested andrelevant document) provided by a Signatory and provide comments as necessary toensure that Corrective Action Plan is fit for purpose.

Monitoring Signatories’ Code Compliance Efforts
7.1

Objective

In accordance with its obligation under Code Articles 20.7.3 and 24.1.1 to monitor Code Complianceby Signatories, WADA reviews Signatories’ rules and regulations (and/or legislation, if that is how
the Code has been implemented in a particular country) to ensure that they are compliant with theCode and the International Standards. WADA also assesses whether Signatories are implementing
their rules, regulations and legislation through Anti-Doping Programs that meet all of therequirements of the Code and the International Standards. The purpose of Article 7 is to set out thestandards that will govern these monitoring activities. The objective will always be to make themonitoring process as efficient and cost-effective as possible.
7.2

Prioritization Between Different Signatories
7.2.1

The following entities may be Signatories to the Code:7.2.1.1

the International Olympic Committee and the International Paralympic
Committee;
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7.2.27.2.1.2other Major Event Organizations;7.2.1.3

International Federations;7.2.1.4

National Olympic Committees and National Paralympic Committees;

7.2.1.5

National Anti-Doping Organizations; and7.2.1.6

other organizations having significant relevance in sport.

Given the large number of Signatories, and WADA’s limited resources, the CRC may
approve proposals by WADA Management to prioritize the monitoring for CodeCompliance (a) of certain categories of Signatories, based on the scope of the AntiDoping Activities required of those Signatories under the Code and the Prioritization
Policy; and/or (b) of certain specific Signatories, based on an objective risk
assessment. The following is a non-exhaustive list of factors that may be consideredin that risk assessment:
7.2.2.1(where the Signatory is an International Federation) the physiological risk of
doping in a particular sport/discipline;

7.2.2.2(where the Signatory is an International Federation) participation of the
Signatory in the Olympic and/or Paralympic Games;

7.2.2.3(where the Signatory is a Major Event Organization) the level of Athletesparticipating in the Event;7.2.2.4

performances by Athletes from a particular country in International Events;

7.2.2.5

a history of doping in a particular country or a particular sport/discipline;

7.2.2.6a Signatory’s response to a Mandatory Information Request or a CodeCompliance Questionnaire;

7.2.2.7

receipt of credible intelligence or the results of an investigation suggesting
there may be significant Non-Conformities in the Signatory’s Anti-Doping
Program;

7.2.2.8a Signatory’s breach of Critical or High Priority requirements under the Codeor an International Standard;

7.2.2.9a Signatory’s failure to implement recommendations following collaboration
programs in which WADA acted as a facilitator or a party;

7.2.2.10 a Signatory’s failure to implement measures (e.g., Target Testing) following
a recommendation made or endorsed by WADA (e.g., in relation to Testingin the lead-up to the Olympic Games or Paralympic Games or other Event);
Page 24 of 62

7.2.2.11 (where the Signatory is a National Anti-Doping Organization or a National
Olympic Committee acting as a National Anti-Doping Organization) the factthat the Signatory’s country hosts a WADA-accredited laboratory and/or is
bidding to host or has won the right to host a major sporting event;7.2.2.12 where a Signatory that has been found to be non-compliant is seeking to be
Reinstated; and/or
7.2.2.13 a request by WADA’s Executive Committee and/or WADA’s Foundation
Board.

7.3

7.2.3

Code Article 20 requires International Federations, National Olympic Committees andNational Paralympic Committees to enforce Code Compliance by theirmembers/recognized bodies. If, in the course of its monitoring activities, WADA learnsof apparent non-compliance with the Code by a member/recognized body of such
Signatory, it will notify the Signatory for appropriate follow-up and action in accordancewith the Signatory’s obligations under the Code.

7.2.4

In addition, again given the large number of Signatories and WADA’s limited
resources, the CRC may approve proposals by WADA Management to prioritize
enforcement of Critical and (in certain circumstances) High Priority requirements of theCode and/or the International Standards (including, where necessary, by alleging noncompliance and proposing imposition of Signatory Consequences), while giving
Signatories additional opportunity to take any corrective action(s) necessary to ensurecompliance with other requirements of the Code and/or the International Standards.
The greatest priority will be given to pursuing the imposition of appropriate Signatory
Consequences in cases involving non-compliance with Critical requirements andAggravating Factors.

7.2.5

WADA may also enlist the support of other bodies to assist it in its monitoring tasks.

7.2.6

For the avoidance of doubt, a Signatory is required to comply in full at all times with its
obligations under the Code and the International Standards, whether or not it isprioritized for monitoring by WADA.

Cooperation with Other Bodies
7.3.1

WADA may cooperate as appropriate with other relevant bodies in promoting full CodeCompliance by Signatories, including (without limitation) with UNESCO in its efforts topromote governments’ compliance with the UNESCO Convention, with the Council ofEurope in its efforts to promote governments’ compliance with its Anti-Doping
Convention, and/or with any other intergovernmental organization or initiative. The
purpose of such cooperation will be to facilitate and maximize the efficacy of WADA’s
own efforts in monitoring Code Compliance by Signatories. Such cooperation shall be
conducted in a manner that respects all applicable data protection laws.

7.3.2

Such cooperation may include (without limitation) coordinating with the other body’s
compliance monitoring activities in relation to a specific country (e.g., joint site visits,coordinated questionnaires), exchange of relevant information that may be ofassistance in such activities, and coordinating actions aimed at assisting andencouraging compliance by relevant parties.
Page 25 of 62

7.4

WADA’s Monitoring Tools
7.4.1

WADA may make use of all legal means at its disposal to monitor Code Complianceby Signatories, including (without limitation):
7.4.1.1

requiring each Signatory, in accordance with Code Article 24.1.2, to complete
and submit Code Compliance Questionnaires and/or other reports on its
Code Compliance within reasonable and clearly communicated timeframes.
Such reports shall provide all information requested by WADA accurately andcompletely, explain the reasons for any Non-Conformities identified, anddescribe the efforts the Signatory has made and/or proposes to make tocorrect such Non-Conformities;

7.4.1.2

conducting Compliance Audits of Signatories’ ongoing Anti-Doping
Programs, in accordance with Article 7.7, in order to assess their CodeCompliance, to identify and categorize Non-Conformities, and to identify
corrective actions required to correct the Non-Conformities;

7.4.1.3

conducting Independent Observer Programs (a) at the Olympic Games andthe Paralympic Games, and (b) at other selected Events;

7.4.1.4

reviewing the adequacy of Signatories’ responses to requests made orendorsed by WADA to implement Target Testing and/or other measures in
the lead-up to the Olympic Games or Paralympic Games or other Event;7.4.1.5

reviewing the following key documents:(a)

Signatories’ rules and regulations (and/or relevant legislation, if that is
how the Code has been implemented in a particular country);(b)

Signatories’ Risk Assessments and Test Distribution Plans provided inaccordance with Code Article 5.4 and Article 4.1.3 of the International
Standard for Testing and Investigations;(c)

Signatories’ annual statistical reports of their respective Doping
Control activities provided in accordance with Code Article 14.4;(d)Doping Control forms, TUE decisions, Results Management
decisions, and other data filed in ADAMS (including assessing
compliance with requirements to file such information in ADAMS within
specified timeframes, and reviewing TUE decisions for compliancewith the International Standard for Therapeutic Use Exemptions);(e)

Signatories’ Education plans and evaluation reports produced inaccordance with Article 18 of the Code and Articles 4 and 6 of theInternational Standard for Education;(f)reports compiled by other relevant bodies (e.g., reports from country
visits conducted by the Monitoring Group of the Anti-Doping
Convention of the Council of Europe); andPage 26 of 62(g)any other documents or data requested by WADA Management fromthe Signatory in order to assess the Signatory’s Code Compliance;

7.4.1.6

conducting other program area monitoring activities in accordance with
Article 7.8;

7.4.1.7

reviewing Results Management decisions made by Signatories andcommunicated to WADA in accordance with Code Articles 7.6 and 14.1.4,
and the International Standard for Results Management, including (without
limitation) decisions by Signatories:(a)

not to bring an Atypical Finding forward as an Adverse Analytical
Finding;(b)

not to bring an Adverse Analytical Finding or an Adverse Passport
Finding forward as an anti-doping rule violation;(c)

not to bring whereabouts failures or other apparent violations forward
as anti-doping rule violations;(d)to withdraw the allegation of an anti-doping rule violation; and(e)to agree on the outcome of proceedings alleging an anti-doping ruleviolation without first holding a hearing;

provided that, save in exceptional cases, WADA will not allege that a
Signatory is non-compliant based solely on a single non-compliant Results
Management decision. Instead, WADA will notify the Signatory within areasonable period following receipt of a material number of Results
Management decisions that WADA Management considers to be noncompliant. Thereafter, WADA will take further action against the Signatory for
non-compliance (by issuing a Corrective Action Report in accordance with
Article 8.2.2) if, notwithstanding such notification, (1) the Signatory fails to put
in place measures reasonably designed to avoid any further non-compliant
Results Management decisions; or (2) WADA receives a further noncompliant Results Management decision for which the Signatory is
responsible;
7.4.1.8

assessing and processing intelligence about potential Non-Conformities
obtained from reliable sources, including but not limited to WADA’sIntelligence and Investigations Department, Signatories and otherstakeholders, WADA-accredited laboratories and other laboratories
approved by WADA, Sample Collection Authorities and/or Sample Collection
Personnel, law enforcement and other relevant authorities (including otherregulatory and/or disciplinary bodies), Athletes and other Persons, whistleblowers, the media, and members of the public;

7.4.1.9

using the powers given to WADA under Code Article 10.7.1 to encourage
Athletes and other Persons to provide information in relation to noncompliance by Signatories;
Page 27 of 62

7.4.1.10 asking WADA’s Intelligence and Investigations Department to follow up on
intelligence regarding, and/or to investigate potential instances of, noncompliance by Signatories; and7.4.1.11 using any other relevant and reliable information or data available to it.

7.5

7.4.2

Where a Signatory is required to provide compliance information to WADA (e.g., in
response to a Code Compliance Questionnaire or a Mandatory Information Request)that is the Signatory’s proprietary and confidential information, WADA will treat that
information confidentially, and will use it to monitor Code Compliance and otherwisein accordance with WADA’s obligations or responsibilities under the Code,International Standards, and applicable laws. As part of its normal reporting/activities,
WADA may also aggregate compliance information provided by Signatories in amanner that does not reveal the particular Signatory to which the information relates,
and may collect, use or disclose such aggregate information for anti-doping purposes.

7.4.3

In carrying out its monitoring activities, WADA will consider potential indications that a
Signatory has systemic compliance issues, such as (for example) anti-doping ruleviolations committed by the Signatory’s board members, directors, officers, and/or
employees, or by a significant number of Athlete Support Personnel under the authorityof the Signatory, or by a large percentage of Athletes under the authority of the
Signatory, particularly where such violations are uncovered by WADA or other third
parties rather than being reported by the Signatory itself.

Code Compliance Questionnaires
7.5.1

Code Article 24.1.2 requires Signatories to report to WADA on their Code Compliancewhen requested by WADA. WADA will send Code Compliance Questionnaires to
Signatories periodically (but no more than once every three (3) years to any given
Signatory) to enable them to self-assess and self-report on their Code Complianceand any potential Non-Conformities. The Code Compliance Questionnaire may require
the Signatory to provide documentation to support and supplement its responses tothe questions in the Code Compliance Questionnaire.

7.5.2

WADA will specify a reasonable date for return of the completed Code Compliance
Questionnaire together with any accompanying documentation. It will send reminders
to Signatories as the date approaches.

7.5.3

Further to Code Article 24.1.3, a failure by a Signatory to return an accurate andcomplete Code Compliance Questionnaire to WADA by the specified date is itself afailure to comply with Code Article 24.1.2 that will trigger the process outlined in Article
8.3.1.

7.5.4

WADA will review the information provided in a completed Code Compliance
Questionnaire to assess the Signatory’s degree of Code Compliance. WADA will seek
to verify a Signatory’s responses to specific questions in the Code Compliance
Questionnaire by reference to information obtained from other, reliable sources, suchas data filed in ADAMS, and independent investigation reports.

7.5.5

Where WADA determines that the Signatory’s completed Code Compliance
Questionnaire does not reveal any Non-Conformities, the Signatory will be duly notified
in writing, but that notification will not affect WADA’s right to seek correction, inPage 28 of 62

accordance with this International Standard for Code Compliance by Signatories, of
any Non-Conformities that WADA did not identify in its review of the Code Compliance
Questionnaire, but instead identifies by other means.
7.5.6

7.6

7.7

Where WADA identifies Non-Conformities based on the Signatory’s completed CodeCompliance Questionnaire, it will issue a Corrective Action Report in accordance with
Article 8.2.2.

Mandatory Information Requests
7.6.1

Independently of any other monitoring activity, where WADA receives or collects
information indicating that a Signatory may not be complying with Critical or HighPriority requirements, WADA Management may send the Signatory a Mandatory
Information Request requiring it to provide information that enables WADA todetermine the actual position. WADA shall only request information that is necessary
for WADA to assess the Signatory’s Code Compliance effectively, and that is notalready available to WADA through other sources (such as ADAMS). The request will
explain why WADA Management is asking for the information and will specify thedeadline for the Signatory to provide it which deadline shall generally be twenty-one(21) days later, but may be shortened or lengthened where WADA Management
deems necessary.

7.6.2

WADA Management will assign a WADA Auditor to review the response received fromthe Signatory and to provide an assessment and recommendation, including (whereappropriate) a recommendation to issue a Corrective Action Report in accordance with
Article 8.2.2.

7.6.3

If the Signatory fails to provide the required response to a Mandatory Information
Request by the date that WADA has specified for receipt of such response, that will
trigger the process outlined in Article 8.3.1.

The Compliance Audit Program
7.7.1

WADA Management will decide (subject to CRC oversight) which Signatories shallundergo a Compliance Audit. The factors listed at Article 7.2.2 may trigger aCompliance Audit. Signatories may also be selected for a Compliance Audit based on
any other relevant reason or credible intelligence collected or received by WADA.

7.7.2

The Compliance Audit will be conducted by WADA Auditors. The Compliance Audit
may be conducted in person (i.e., where the audit team visits the Signatory andconducts the assessment of the Signatory’s Anti-Doping Program in the presence of
relevant members of the Signatory’s team), or virtually (e.g., using a teleconference
system), or via an exchange of written information initiated by a request from WADA,
such as a Mandatory Information Request.

7.7.3

In each case, the Signatory shall cooperate with WADA and the WADA audit team in
all aspects of the Compliance Audit. A lack of cooperation may be referred by WADA
Management to the CRC for consideration as a potential Non-Conformity.

7.7.4

Arranging an in-person Compliance Audit:
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7.7.4.1

WADA will send the Signatory a notice of its selection for a Compliance Audit,
the names of the lead auditor and the other members of the audit team, andthe dates on which the audit team proposes to visit the Signatory’s offices to
conduct the audit (which is usually two to three (2-3) days in duration). The
dates identified should give the Signatory at least one (1) month to prepare
for the audit visit. In the same notice, WADA will provide a date by which the
Signatory shall submit a number of documents required by the audit team toprepare for the audit.

7.7.4.2

The Signatory has fourteen (14) days to respond to the notice withconfirmation that the dates proposed for the audit are convenient, or
explaining why those dates are not convenient and proposing alternative
dates that are as close as possible to the dates proposed by WADA.

7.7.4.3

A Signatory’s refusal to be audited or failure to cooperate in finding
appropriate dates for an audit or to provide on a timely basis the documents
requested in the notice constitutes a Non-Conformity with Code Article 24.1.2
and, unless corrected immediately following receipt of a written notice from
WADA, will trigger the process set out in Article 8.3.1.

7.7.4.4

Once the dates are confirmed, WADA will send the Signatory an audit plan
providing guidance on the scope of the audit to be conducted and on how to
prepare for the audit visit.

7.7.4.5

At least fourteen (14) days prior to the audit visit, the lead auditor should
communicate directly (e.g., by telephone call or by in-person meeting) with
the Signatory’s main contact for compliance matters, in order to confirm allnecessary arrangements, answer any questions on the audit, and discuss
how information should be prepared and presented by the Signatory to theaudit team.

7.7.5

In all cases, the Signatory shall facilitate the visit of the WADA audit team, including
arranging for appropriate staff to be present during the audit visit, and providing thenecessary meeting and related facilities for the WADA audit team to carry out theCompliance Audit. If the Signatory delegates any part of its Anti-Doping Program to a
Delegated Third Party, the Signatory shall ensure that representatives of theDelegated Third Party are available to answer questions from the WADA audit teamand provide any requested documentation or information during the audit.

7.7.6

At the opening meeting of the audit, the audit team will explain the approach it will takefor the Compliance Audit, confirm the scope of the audit, and explain what it expects
from the Signatory in terms of cooperation and support for the audit. It will give the
Signatory the opportunity to ask any questions in relation to the audit.

7.7.7

During the Compliance Audit, the audit team will assess the Signatory’s Anti-Doping
Program using information from different sources, including the Signatory’s completed
Code Compliance Questionnaire, data filed in ADAMS, independent investigation
reports, intelligence collected or received, media reports that WADA considers reliable,
and any other reliable information available to it. The audit team will seek out
representative examples and evidence of the work conducted by the Signatory as partof its Anti-Doping Program, noting any discrepancies between such examples andevidence and the information that the Signatory has provided (e.g., in its Code
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Compliance Questionnaire). The Signatory shall cooperate in providing the audit teamwith full access to all information, procedures, and systems required to complete theCompliance Audit.
7.7.8

At the closing meeting, the audit team will verbally present its preliminary findings to
the Signatory, including identifying any apparent Non-Conformities (focusing on
Critical and High Priority requirements). The audit team may also outline any findings
and/or best practice recommendations in respect of General requirements. The
Signatory will be given an opportunity to note any disagreement with the audit team’s
preliminary findings during the closing meeting. The audit team will also outline thelikely follow-up process and timeframes in terms of corrective actions, so that the
Signatory may start addressing the findings immediately, i.e., without waiting for the
Corrective Action Report. Following completion of the audit, the lead auditor will
present the final audit findings in a draft Corrective Action Report to WADA
Management. For the avoidance of doubt, following further consideration by the audit
team, the final audit findings may be more extensive than the preliminary findingspresented verbally at the closing meeting. As soon as practicable thereafter, a final
Corrective Action Report will be issued to the Signatory in accordance with Article
8.2.2.

7.7.9

WADA will pay the costs of the Compliance Audit, subject to potential reimbursementby the Signatory in accordance with Article 11.2.1.4.

7.7.10 WADA will publish on its website a list of Signatories that have undergone aCompliance Audit. Once an audit is complete, and the Signatory in question hasreceived the final Corrective Action Report, WADA may publish a summary of the audit
outcomes.
7.7.11 Where WADA determines that the Signatory’s Compliance Audit does not reveal any
Non-Conformities, the Signatory will be duly notified in writing. For the avoidance of
doubt, WADA shall have the right to seek correction, in accordance with thisInternational Standard for Code Compliance by Signatories, of any Non-Conformities
that were not identified as part of the Compliance Audit, but instead are identified byother means. The fact that the Compliance Audit did not identify those NonConformities will not affect that right.
7.8

Program Area Monitoring
7.8.1

In consultation with the CRC, WADA Management will identify a number ofrequirements for which Signatories will be subject to specific program area compliancemonitoring, using means that are complementary to the Code Compliance
Questionnaire and Compliance Audits.

7.8.2

The relevant department within WADA will be responsible for the program area
monitoring of each Signatory’s compliance with the requirement(s) in question.
Appropriate timeframes and reminders will be established and communicated to the
Signatories with sufficient time afforded to correct any Non-Conformity.

7.8.3

If the Signatory does not correct a Non-Conformity within the timeframe set by therelevant WADA department, the department will report the Non-Conformity to WADA
Management, which will issue a Corrective Action Report in accordance with Article
8.2.2.
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7.8.4

7.9

In addition to the program area monitoring, Signatories that have been subject to aCompliance Audit may have any Non-Conformities with Critical or High Priority
requirements that were identified at the time of the audit reviewed after the completionof the post-audit Corrective Action Report. The relevant WADA department will assess
whether the Critical and High Priority requirements are still being met by reference toany information to which WADA has access, including via a Mandatory Information
Request. Should the relevant WADA department identify any Non-Conformities with
Critical or High Priority requirements, WADA will issue a Corrective Action Report inaccordance with Article 8.2.2.

Special Provisions Applicable to Major Event Organizations
7.9.1

The International Olympic Committee, the International Paralympic Committee, andother Major Event Organizations are subject to the same Code Compliance monitoringand enforcement rules and procedures set out in this International Standard for CodeCompliance by Signatories as all other Signatories. However, they may also be madethe subject of an Independent Observer Program; and the normal procedures for
identification and correction of Non-Conformities may have to be fast-tracked for them,in the manner set out in this Article 7.9, due to the timing of their Events. For the
avoidance of doubt, unless otherwise stated in this Article 7.9, the normal rules,
procedures, and timeframes set out in this International Standard for Code Complianceby Signatories shall apply to the International Olympic Committee, the International
Paralympic Committee, and other Major Event Organizations.

7.9.2

WADA may send to a Major Event Organization a Code Compliance Questionnaire
tailored for Major Event Organizations one (1) year or less before its Event is to bestaged. The Major Event Organization shall complete and return that CodeCompliance Questionnaire to WADA within a reasonable timeframe specified by
WADA that gives WADA sufficient time to identify and the Major Event Organization
sufficient time to correct any Non-Conformities before the Event takes place. The CodeCompliance Questionnaire as completed by the Major Event Organization mustdescribe in adequate detail the Anti-Doping Program that the Major Event Organization
proposes to put in place for the Event, so that any Non-Conformities can be identified
and corrected in advance.

7.9.3

Where WADA identifies Non-Conformities based on the Major Event Organization’s
completed Code Compliance Questionnaire, it will issue a Corrective Action Report inaccordance with Article 8.2.2, save that where the Corrective Action Report:
7.9.3.1

identifies Non-Conformities with Critical requirements, the Signatory shallcorrect them within a timeframe specified by WADA of no more than two (2)months; and/or

7.9.3.2

identifies Non-Conformities with High Priority requirements, the Signatory
shall correct them within a timeframe specified by WADA of no more thanfour (4) months; and/or

7.9.3.3

identifies Non-Conformities with General requirements, the Signatory shallcorrect them within a timeframe specified by WADA of no more than six (6)months.
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7.9.4

Where a Major Event Organization fails to correct Non-Conformities within thetimeframe specified by WADA, WADA Management shall follow the standard
corrective procedures and timeframes set out in Articles 8.1 to 8.3, save that where
the urgency of the matter/the timing of the Event means that such standard procedures
and timeframes are not appropriate, WADA Management may impose shorter
timeframes (provided it informs the Major Event Organization of the shortened
timeframes and of the consequences of failing to meet them) and/or may refer thecase to the CRC for urgent consideration without following all of the steps set out in
Articles 8.1 to 8.3.
7.9.4.1

7.9.5

In such cases, WADA Management shall give the Major Event Organization
an opportunity to explain the apparent Non-Conformities by a specified dateand shall communicate any explanation provided by the Signatory within thatdate to the CRC.

When WADA Management refers a case to the CRC in accordance with this Article
7.9:
7.9.5.1

The CRC will convene (either in person or otherwise) as soon as possible toconsider the matter. It will consider WADA Management’s assessment, andany explanation or comments provided by the Major Event Organization inaccordance with Article 7.9.4.1.

7.9.5.2

Following such review, if the CRC considers that a fast-track procedure is not
required, it may recommend:(a)that a mission in the framework of the Independent Observer Program
be conducted at the Major Event Organization’s Event (if not planned
already); and/or(b)that a Corrective Action Report be issued to the Signatory, to befollowed up in accordance with fast-track procedures that ensure theNon-Conformities are corrected well in advance of the next edition of
the Event in question; and/or(c)that the Major Event Organization contract with a Delegated Third Party
to support its Anti-Doping Activities at the Event.

7.9.6

If, however, the CRC considers that a fast-track procedure is required, Articles 8.5.4.3
and 8.5.4.4 shall apply.

7.9.7

Whether or not Article 7.9.6.2(a) applies:
7.9.7.1

In accordance with Article 7.4.1.3, as an additional means of monitoring CodeCompliance by Major Event Organizations, WADA may conduct Independent
Observer Programs (a) at the Olympic Games and the Paralympic Games;(b) at continental Games (e.g., African Games, Asian Games, European
Games, Pan American Games), as well as the Commonwealth Games andWorld Games; and (c) at other Events, to be selected based on objective
criteria agreed with the CRC.

7.9.7.2

Where WADA has issued a Corrective Action Report for a Major Event
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Organization in accordance with Article 7.9.3, one of the tasks of the
Independent Observer Program sent to that Major Event Organization’s next
Event will be to determine whether the Major Event Organization has
implemented the corrective actions identified in that Corrective Action Report.
If the corrective actions have not been properly implemented, they will bereferenced in the report issued by the Independent Observer Program andpublished by WADA after the Event in question, along with any other NonConformities identified by the Independent Observer Program during the
Event.
[Comment to Article 7.9.7.2: Information provided by the Major Event Organization
in a Code Compliance Questionnaire and/or a Corrective Action Report, as well as
WADA’s responses thereto, shall be taken into account by the Independent Observer
Program in order to avoid, where possible, a duplication of the review of thoseelements (e.g., policies, documents, protocols, etc.) already addressed as part of theCode Compliance Questionnaire or Corrective Action Report process].

7.9.7.3

8.0

When the report issued by the Independent Observer Program is completed,
all Non-Conformities will also be included in a new Corrective Action Report,
requiring (as WADA sees fit) either (a) the implementation of the corrective
actions within specified timeframes (which may or may not be the same
timeframes as are set out in Article 7.9.3), or (b) a commitment to implement
the corrective actions before the next edition of the Major Event
Organization’s Event.

Giving Signatories the Opportunity to Correct Non-Conformities
8.1

8.2

Objective
8.1.1

When Non-Conformities are identified, the objective will be to assist the Signatory
through dialogue and support to correct the Non-Conformities and so achieve andmaintain full Code Compliance.

8.1.2

Article 8 sets out the procedures that WADA will follow in giving the Signatory adequate
opportunity to correct the Non-Conformities identified. The various steps in the process
are presented in flow chart format in Figure One (Article 5 above).

Corrective Action Reports and Corrective Action Plans
8.2.1

Where the Signatory’s rules or regulations (or applicable legislation, if that is how theCode has been implemented in a particular country) are not compliant with the Code,WADA Management will give the Signatory a Corrective Action Report that identifies
the Non-Conformities and specifies a timeframe of no more than three (3) months for
the Signatory (i) to adopt amendments that correct them in a manner acceptable to
WADA; or (ii) to provide (a) appropriate draft amendments that would correct them ina manner acceptable to WADA and (b) a commitment to bring those amendments into
effect within a confirmed timeframe that is acceptable to WADA.

8.2.2

Where WADA identifies Non-Conformities in any other aspects of a Signatory’s AntiDoping Program (whether as a result of a Code Compliance Questionnaire or aCompliance Audit, or as a result of information provided in response to a Mandatory
Information Request, or otherwise), WADA Management will send the Signatory a
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Corrective Action Report that:
8.2.2.1

identifies Non-Conformities with Critical requirements, which the Signatory
shall correct within a timeframe specified by WADA of no more than three (3)months; and/or

8.2.2.2

identifies Non-Conformities with High Priority requirements, which the
Signatory shall correct within a timeframe specified by WADA of no morethan six (6) months; and/or

8.2.2.3

identifies Non-Conformities with General requirements, which the Signatory
shall correct within a timeframe specified by WADA of no more than nine (9)months;unless the Signatory is a Major Event Organization, in which case the above
timeframes will not apply, and instead the matter will be addressed inaccordance with Article 7.9.

8.2.3

Having sent the Corrective Action Report, WADA Management will establish that the
Signatory has received the Corrective Action Report, and will seek to ensure that the
Signatory understands what it needs to do to implement the required corrective actions
within the specified timeframes.

8.2.4

If the Signatory disputes one or more of the Non-Conformities identified in the
Corrective Action Report, and/or disputes their classification as Critical or High Priority,
WADA Management will review the position. If the position is maintained following that
review, the Signatory may request that the dispute be referred to the CRC inaccordance with Article 8.4.1. Following such referral, the compliance procedure will
be stayed, and WADA Management will take no further steps in the matter, until adecision has been made by the CRC or by WADA’s Executive Committee (asapplicable). If the CRC agrees with the view of WADA Management, the matter shallproceed in accordance with this International Standard for Code Compliance by
Signatories. If the CRC does not agree with the view of WADA Management, WADA
Management may refer the issue to WADA’s Executive Committee for decision. In
either event, the Signatory may continue to dispute the Non-Conformities and/or theirclassification in the subsequent proceedings.

8.2.5

Subject always to Article 8.1.2, the Signatory shall correct the Non-Conformities within
the timeframes specified in the Corrective Action Report. The Corrective Action Reportwill include within it a Corrective Action Plan section for the Signatory to complete, inorder to assist the Signatory in planning who within its organization will implement eachof the corrective actions, how, and by when. It is not mandatory for the Signatory toprovide a Corrective Action Plan to WADA but it is strongly recommended. If the
Signatory provides a Corrective Action Plan, WADA will review that plan to confirm it
is fit for purpose. If it is not fit for purpose, WADA will provide comments to assist the
Signatory to make it fit for purpose.

8.2.6

WADA Management will monitor the Signatory’s progress in correcting the NonConformities identified in the Corrective Action Report.
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8.2.78.3

8.4

If any further Non-Conformities are discovered after a Corrective Action Report has
been sent to the Signatory but before the matter has been referred to the CRC, or if
there is a repeat of a Non-Conformity that was supposedly corrected before the matterhas been referred to the CRC, WADA Management may send the Signatory an
updated Corrective Action Report that adds the new Non-Conformities and thatprovides a new timeframe or timeframes for correction of all the Non-Conformities
identified in the updated Corrective Action Report.

Final Opportunity to Correct before Referral to the CRC
8.3.1

If a Signatory does not correct all Non-Conformities within the timeframe set in the
Corrective Action Report, or if a Signatory fails to provide the required response within
the specified timeframe to a Code Compliance Questionnaire, a notice of aCompliance Audit, a request made as part of program area monitoring, or a Mandatory
Information Request, WADA Management will give the Signatory written notice of that
failure and a new timeframe of anything up to, but no more than, three (3) months tocorrect it. That new timeframe will not be extended again, unless the Signatory
establishes that an Event of Force Majeure will make it impossible for the Signatory tocorrect the position within that timeframe.

8.3.2

If any further Non-Conformities (whether new or repeated) are discovered, , after the
Signatory has been given a new timeframe to correct the original Non-Conformities
pursuant to Article 8.3.1 but before the matter has been referred to the CRC, WADA
Management will send the Signatory notice of the further Non-Conformities and set a
timeframe (which may, where appropriate, be on a fast track basis) in which all of the
Non-Conformities (i.e., original and further) shall be corrected. Thereafter, all of the
Non-Conformities will be addressed together, in one merged procedure.

Referral to the CRC
8.4.1

If a Signatory (a) continues to dispute an alleged Non-Conformity after an exchangeof views with WADA Management and requests referral of the matter to the CRC; or(b) does not correct a Non-Conformity by the timeframe set in accordance with Article
8.3.1; or (c) does not provide the required response to a Mandatory Information
Request or Code Compliance Questionnaire by the timeframe set in accordance with
Article 8.3.1, WADA Management will refer the matter to the CRC for consideration inaccordance with Articles 8.4.2 to 8.4.6. Following such referral, the compliance
procedure will be stayed, and WADA Management will take no further steps in thematter, until a decision has been made by the CRC or by WADA’s Executive
Committee (as applicable) further to Articles 8.4.2 to 8.4.6.

8.4.2

WADA Management will advise the Signatory of the decision to refer the matter to the
CRC, and explain that the Signatory may submit any explanations or other commentsthat the Signatory wishes the CRC to consider. WADA Management will communicate
to the CRC any explanation or comments received from the Signatory.

8.4.3

In all cases, the CRC shall review and determine for itself whether it agrees with WADA
Management’s classification of the Non-Conformities as Critical, High Priority, orGeneral. If not, they shall be re-classified (and the timeframes for corrective action
shall be amended accordingly) (unless WADA Management maintains its position, in
which case WADA’s Executive Committee shall decide). The CRC shall also consider
fully and fairly any explanations or comments received from the Signatory in respect
Page 36 of 62

of those Non-Conformities. In particular, any Event of Force Majeure that may explain
the Signatory’s Non-Conformities or inability to correct them as required by theCorrective Action Report shall be fully and fairly considered in accordance with Article
8.6.

8.5

8.4.4

Where the CRC considers that the Signatory has failed without valid reason to correct
the Non-Conformity/ies in question or to respond to a Mandatory Information Requestor Code Compliance Questionnaire satisfactorily within the specified timeframe, theCRC will provide to WADA’s Executive Committee a report of the relevant facts andan explanation of why, based on those facts, the CRC recommends that the Signatory
be sent a formal notice alleging that it is non-compliant with the requirements of theCode and/or the International Standards. The report should also categorize therequirements in question as Critical, High Priority, or General, identify any Aggravating
Factors, recommend in accordance with Article 10 particular Signatory Consequences
to be proposed in the formal notice for such non-compliance, and recommend inaccordance with Article 11 the conditions to be proposed in the formal notice that the
Signatory should be required to satisfy in order to be Reinstated.

8.4.5

Alternatively, if the Signatory has provided a Corrective Action Plan that explains tothe satisfaction of the CRC how the Signatory will correct the Non-Conformities withinfour (4) months, the CRC may recommend that WADA’s Executive Committee decide(a) to give the Signatory that period (starting to run from the date of the Executive
Committee’s decision) to correct the Non-Conformities, and (b) that the formal noticedescribed in Article 8.4.4 shall be sent to the Signatory upon expiry of that timeframe(without the need for a further decision by WADA’s Executive Committee) if the CRC
considers that the Non-Conformities have not been corrected in full by then. This
option is referred to as the Watchlist Procedure.

8.4.6

In either case, in applying the principles set out in Article 10, the CRC will assess andconsider in making its recommendation the potential impact on third parties (including
in particular Athletes) of any Signatory Consequences proposed. WADA Management
will be responsible for ensuring that the CRC is fully informed of this potential impact.

Fast-Track Procedure
8.5.1

Unless otherwise specified, where there is a Non-Conformity by a Signatory with one
or more Critical requirements of the Code and/or the International Standards, this
Article 8.5:
8.5.1.1

shall apply where WADA considers that urgent intervention is required inorder to maintain confidence in the integrity of a sport or sports and/or of aparticular Event or Events and/or in the integrity of a Signatory’s Anti-Doping
Activities;

8.5.1.2

may be applied (where WADA sees fit):(a)where WADA considers that the Non-Conformity is similar to one ormore of that Signatory’s past Non-Conformities (whether or not thosepast Non-Conformities have since been corrected);(b)

to cases involving Major Event Organizations, where the timing of the
Event in question so requires, as described in Article 7.9; andPage 37 of 62

(c)to cases involving original and further Non-Conformities, as describedin Article 8.3.2.

8.5.2

WADA Management shall or may (as applicable) refer a case that falls within Article
8.5.1 to the CRC for urgent consideration without following all of the steps set out inthe preceding Articles of this International Standard for Code Compliance by
Signatories. Alternatively, WADA Management may follow some or all of those steps
but with shortened timeframes, according to the urgency of the matter, and refer thecase to the CRC if the Signatory has not corrected the Non-Conformities within the
shortened timeframes.

8.5.3

In such cases, WADA Management shall give the Signatory an opportunity to explain
the apparent Non-Conformities within a specified timeframe, and shall communicate
any explanation provided by the Signatory within that timeframe to the CRC.

8.5.4

When WADA Management refers a case to the CRC in accordance with this Article:
8.5.4.1

The CRC will convene (in person or otherwise) as soon as possible toconsider the matter. It will consider WADA Management’s assessment, andany explanation or comments provided by the Signatory in accordance with
Article 8.5.3.

8.5.4.2

Following such review, if the CRC considers that a fast-track procedure is not
required, it may recommend:(a)that the Signatory undergo a Compliance Audit; and/or(b)that a Corrective Action Report be issued to the Signatory, to befollowed up in accordance with the normal procedures set out in Articles
8.3 and/or 8.4.

8.5.4.3

If, however, the CRC considers that a fast-track procedure is required, theCRC may recommend to WADA’s Executive Committee that the Signatory
be sent a formal notice alleging that it is (or was, as applicable) non-compliant
with Critical requirements of the Code and/or the International Standards,
identifying any Aggravating Factors alleged by WADA, specifying the
Signatory Consequences that it is contended should apply for such noncompliance (in accordance with Article 10) (including any such Signatory
Consequences that the CRC considers should be imposed urgently to protect
the rights of clean Athletes and/or to maintain confidence in the integrity ofsport and/or of a particular Event or Events), and specifying the conditions
that it is proposed the Signatory should have to satisfy in order to be
Reinstated (in accordance with Article 11).

8.5.4.4

If WADA’s Executive Committee accepts that recommendation (by votetaken at an in-person meeting or, if necessary to avoid delay, by
teleconference or by circular email communication), that formal notice shallbe sent to the Signatory in accordance with Article 9.2.3. At the same time,or at any time thereafter, WADA may refer the case to the CAS Ordinary
Arbitration Division and may apply to CAS for appropriate interim relief inaccordance with Article 9.4.4, and/or for an expedited hearing on the merits.
Page 38 of 62

8.6

Event of Force Majeure
8.6.1 Where a Signatory demonstrates that one or more of its Non-Conformities or its
inability to correct them as required by the Corrective Action Report is due to an Eventof Force Majeure, WADA’s Executive Committee (having taken into account any
recommendation made by the CRC on the issue) may in its discretion either: (1) delay
and/or suspend any non-compliance procedure against the Signatory while the Eventof Force Majeure continues to have that effect, while reserving the right to pursue thenon-compliance procedure once that effect ends (having taken into account any
recommendation made by the CRC on the issue); or (2) waive the relevant NonConformities and close the non-compliance procedure. WADA’s determination as towhether to delay and/or suspend the procedure or waive the Non-Conformities is not
subject to challenge, whether by way of appeal or otherwise.

9.0

Confirming Non-Compliance and Imposing Signatory Consequences
9.1

CRC Recommendation
9.1.1

9.2

Articles 8.4 and 8.5 identify the circumstances in which the CRC may recommend that
the Signatory be sent a formal notice alleging non-compliance with the requirementsof the Code and/or the International Standards, categorizing the requirements inquestion as Critical, High Priority, or General, identifying any Aggravating Factors
alleged by WADA (in cases involving non-compliance with Critical requirements), andspecifying the Signatory Consequences that it is contended should apply for such noncompliance (in accordance with Article 10), as well as the conditions that it is proposed
the Signatory should have to satisfy in order to be Reinstated (in accordance with
Article 11).

Consideration by WADA’s Executive Committee
9.2.1

At its next meeting in person, or else (if the CRC so recommends) by teleconference
or by circular email communication, WADA’s Executive Committee will decide whether
to accept the CRC’s recommendation. The CRC’s recommendation and the decisionof WADA’s Executive Committee in respect of that recommendation shall be madepublic (e.g., by publication of the minutes of WADA’s Executive Committee’s
deliberations on the matter) no more than fourteen (14) days after WADA’s Executive
Committee makes its decision.

9.2.2

If WADA’s Executive Committee does not accept all or any part of the CRC’s
recommendation, it shall not substitute its own decision but instead shall remit thematter back to the CRC so that the CRC may consider the matter further and decide
how to proceed (e.g., by making a revised recommendation to WADA’s Executive
Committee). If WADA’s Executive Committee also does not accept the CRC’s second
recommendation on the matter, it may either refer the matter back to the CRC again
or else take its own decision on the matter, as it sees fit.

9.2.3

Where WADA’s Executive Committee decides to accept the CRC’s recommendation
to issue a formal notice of non-compliance to a Signatory (whether immediately, or
automatically upon expiry of the timeframe specified in accordance with Article 8.4.5,
if the CRC concludes that the Non-Conformities have still not been corrected by then),
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WADA shall issue such formal notice to the Signatory, setting out the mattersreferenced at Article 9.1.1. The process thereafter is set out in flow chart format in
Figure Two (see Article 5, above).

9.3

9.2.4

Where the Signatory Consequences proposed in the formal notice may affectattendance at/participation in the Olympic Games or Paralympic Games, WADA shallcopy the notice formally to the International Olympic Committee and/or theInternational Paralympic Committee (as applicable).

9.2.5

The formal notice sent to the Signatory (or a summary thereof) shall be publicly
reported on WADA’s website and sent to WADA’s stakeholders once that notice has
been received by the Signatory. WADA’s stakeholders may assist in the publicizing of
the notice, such as by publicly reporting it on their own websites.

Acceptance by the Signatory
9.3.1

The Signatory will have twenty-one (21) days from the date of receipt of the formal
notice to dispute WADA’s allegation of non-compliance and/or the Signatory
Consequences and/or the Reinstatement conditions proposed by WADA in the notice.
Further to Code Article 24.1.5, if the Signatory does not communicate such dispute inwriting to WADA within twenty-one (21) days (or such extended timeframe as WADA
may agree), the allegation will be deemed admitted, the Signatory Consequences
and/or the Reinstatement conditions proposed by WADA in the notice will be deemed
accepted, and the notice will automatically become a final decision that is enforceable(subject to Article 9.3.2) with immediate effect in accordance with Code Article 24.1.9.
This outcome will be publicly reported by WADA.
9.3.1.1

Alternatively, if the Signatory asserts that it has corrected the non-compliancein full within twenty-one (21) days of receipt of the formal notice, WADA
Management will refer the matter to the CRC. If the CRC is satisfied that the
non-compliance has been corrected in full, it will recommend to WADA’s
Executive Committee that the formal notice be withdrawn (subject, whereappropriate, to certain conditions, e.g., that the Signatory pays the costs
incurred by WADA in relation to the non-compliance). If the CRC is notsatisfied that the non-compliance has been corrected in full, WADA will resend the formal notice (amended if necessary, at the direction of the CRC)
to the Signatory, giving it another twenty-one (21) days from the date ofreceipt of the notice either to dispute or to accept the contents of the notice.

9.3.1.2

Alternatively, if within twenty-one (21) days of receipt of the formal notice the
Signatory provides a Corrective Action Plan that explains to the satisfactionof the CRC how the Signatory will correct the Non-Conformities within four(4) months of WADA’s Executive Committee’s decision, the CRC may
recommend that WADA’s Executive Committee apply the Watch-List
Procedure (subject, where appropriate, to certain conditions, e.g., that the
Signatory pays the costs incurred by WADA in relation to the noncompliance).

9.3.1.3

If the Signatory corrects the non-compliance in full at a later stage in theprocess, WADA’s Executive Committee will decide (taking into account therecommendation of the CRC) whether to discontinue the process
immediately, or to continue the process until (a) appropriate Signatory
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Consequences have been accepted by or imposed on the Signatory inrespect of the non-compliance; and/or (b) the Signatory has paid the costs
incurred by WADA in relation to the non-compliance.
9.3.2

9.4

WADA will post on its website the final decision referred to in the opening paragraphof Article 9.3.1. Any party that would have been entitled as of right under Code Article
24.1.7 to intervene in the CAS proceedings that would have taken place if the
Signatory had disputed any aspect of WADA’s notice shall have the right to appeal
against Signatory Consequences imposed pursuant to that decision to the extent thatthey impact upon that party (but not against any other aspect of the decision), by filingan appeal with CAS within twenty-one (21) days of WADA posting that decision on its
website. That party may ask CAS for interim measures suspending enforcement of the
Signatory Consequences as against that party pending the outcome of the appeal, on
the basis that the appeal would then be dealt with on an expedited basis. If CAS makesthat order, the decision will be final and enforceable immediately in respect of all other
Signatories but not against that party unless and until (and to the extent that) the CAS
rejects that party’s appeal. The appeal shall be resolved by the CAS Appeals
Arbitration Division in accordance with the CAS Code of Sports-related Arbitration andMediation Rules and this International Standard for Code Compliance by Signatories(and in the case of conflict between them, the latter shall prevail). Swiss law will govern
the proceedings. The seat of the arbitration, and the venue of any hearings, shall be
Lausanne, Switzerland. Unless the parties agree otherwise, the proceedings will be
conducted in English and the CAS Panel that hears and determines the dispute will becomposed of three (3) arbitrators. WADA and the Signatory shall each nominate anarbitrator to sit on the CAS Panel, choosing either from the list of arbitrators specificallydesignated by CAS for cases arising under Code Article 24.1 or from the general CAS
list of arbitrators, as each sees fit, and those two (2) arbitrators shall together choosea third arbitrator from the former list to act as President of the CAS Panel. If they cannot
agree within three (3) days, the President of the CAS Appeal Arbitration Division will
choose the President of the CAS Panel from the former list. Cases shall be completed
expeditiously and (save in exceptional circumstances) the reasoned decision shall be
issued no later than three (3) months after the date of appointment of the CAS Panel.
That decision shall be publicly reported by CAS and the parties.

Determination by CAS
9.4.1

If the Signatory disputes the alleged non-compliance and/or the proposed Signatory
Consequences and/or the proposed Reinstatement conditions, then (in accordancewith Code Article 24.1.6) it shall notify WADA in writing within twenty-one (21) days of
its receipt of the notice from WADA. WADA shall then file a formal notice of disputewith CAS, and the dispute will be resolved by the CAS Ordinary Arbitration Division inaccordance with the CAS Code of Sports-related Arbitration and Mediation Rules andthis International Standard for Code Compliance by Signatories (and in the case of
conflict between them, the latter shall prevail). Swiss law will govern the proceedings.
The seat of the arbitration, and the venue of any hearings, shall be Lausanne,
Switzerland. Unless the parties agree otherwise, the proceedings will be conducted in
English and the CAS Panel that hears and determines the dispute will be composedof three (3) arbitrators. WADA and the Signatory shall each nominate an arbitrator tosit on the CAS Panel either from the list of arbitrators specifically designated by CAS
for cases arising under Code Article 24.1 or from the general CAS list of arbitrators, aseach sees fit, and those two (2) arbitrators shall together choose a third arbitrator fromthe former list to act as the President of the CAS Panel. If they cannot agree within
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three (3) days, the President of the CAS Ordinary Arbitration Division will choose thePresident of the CAS Panel from the former list. Third parties may intervene or apply
to intervene (as applicable) as set out in Code Article 24.1.7 but solely to address any
proposed Signatory Consequences that would impact upon them. Cases shall becompleted expeditiously and (save in exceptional circumstances) the reasoned
decision shall be issued no later than three (3) months after the date of appointmentof the CAS Panel. That decision shall be publicly reported by CAS and the parties.
9.4.2

If the Signatory has disputed WADA’s allegation that the Signatory is non-compliant
with the Code and/or the International Standards, WADA shall have the burden ofproving, on the balance of probabilities, that the Signatory is non-compliant as alleged.
If the CAS Panel decides that WADA has met that burden, and if the Signatory has
also disputed the Signatory Consequences and/or the Reinstatement conditions
specified by WADA, the CAS Panel will also consider, by reference to the provisionsof Article 10, what Signatory Consequences should be imposed and/or, by reference
to the provisions of Article 11, what conditions the Signatory should be required tosatisfy in order to be Reinstated.

9.4.3

Consistent with the principle of ‘last resort’, in any case (including not only ordinary but
also fast-track cases), if a Signatory does not meet the required timeframes forcorrecting Non-Conformities, and therefore the case is referred to the CRC, if the
Signatory corrects the Non-Conformities to the satisfaction of the CRC at any time
before Signatory Consequences are imposed by CAS, then WADA may agree that no
Signatory Consequences will be imposed other than (a) a requirement for the
Signatory to reimburse the costs that WADA has incurred in investigating the caseand/or in pursuing the case before CAS; and/or (b) where the failure to correct a NonConformity within the required timeframe has resulted in irreparable prejudice,
Signatory Consequences may be imposed that reflect that prejudice.

9.4.4

No Signatory Consequences that are disputed by the Signatory will come into effectunless and until CAS so orders.. For the avoidance of doubt, however, nothing shallprevent WADA, where necessary, from asking CAS to issue interim measures pending
resolution of the dispute. In such cases, any third party that has intervened pursuant
to Code Article 24.1.7 has a right to be heard on the application for interim measures,to the extent it would be impacted by those measures. If the interim measures are
granted, the Signatory and any such third party shall have no right of appeal against
those interim measures but instead shall have the right to an expedited hearing on the
merits of the case. If the interim measures are not granted, CAS may issue directions
for an expedited hearing on the merits of the case.
9.4.4.1

9.5

Where necessary (for example, to avoid the risk of destruction of evidence),
WADA may make the request for interim measures ex parte, even before thematter is brought to WADA’s Executive Committee or a formal notice of the
dispute is sent to the Signatory in question. In such cases, if the interim
measures are granted, the Signatory (and any third party intervenor, to theextent it is impacted by those measures) shall have a right of appeal against
those interim measures to the CAS Appeals Arbitration Division.

Recognition and Enforcement by Other Signatories
9.5.1

Once a decision as to a Signatory’s non-compliance is final (either because the
Signatory did not dispute the contents of WADA’s formal notice sent in accordance
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with Article 9.2.3, or because the Signatory did dispute it but CAS ruled against the
Signatory), in accordance with Code Article 24.1.9 that decision shall be applicableworldwide and shall be recognized, respected and given full effect by all other
Signatories in accordance with their authority and within their respective spheres of
responsibility.
9.5.2
9.6

Signatories shall ensure that they have due authority under their statutes, rules andregulations to comply with this requirement in a timely manner.

Disputes about Reinstatement
9.6.1

If a Signatory wishes to dispute WADA’s allegation that the Signatory has not yet met
Reinstatement conditions imposed on it and therefore is not yet entitled to be
Reinstated, it shall advise WADA in writing within twenty-one (21) days of its receiptof the allegation from WADA (see Code Article 24.1.10). WADA shall then file a formal
notice of dispute with CAS, and the dispute will be resolved by the CAS Ordinary
Arbitration Division in accordance with Code Articles 24.1.6 to 24.1.8 and this Article
9.

9.6.2

It will be WADA’s burden to prove on the balance of probabilities that the Signatory
has not yet met the Reinstatement conditions imposed on it and therefore is not yet
entitled to be Reinstated. If the case was previously considered by a CAS Panel further
to Code Article 24.1.6, if possible, the same CAS Panel shall be constituted to hearand determine this new dispute.

10.0 Determining Signatory Consequences
10.1 Potential Signatory Consequences
10.1.1 The Signatory Consequences that may be imposed, individually or cumulatively, for a
Signatory’s Non-Conformity, based on application of the principles set out in Article
10.2 to the particular facts and circumstances of the case at hand, are set out at Code
Article 24.1.12.
10.1.2 As set out in Annex B, certain Signatory Consequences are specific to particular typesof Signatory.
10.1.2.1 Where the non-compliant Signatory acts as both an International Federation
and a Major Event Organization, then (whether the requirement in question
was imposed on it as an International Federation, or as a Major Event
Organization, or both): (1) it shall be subject to the Signatory Consequences
applicable to both types of organization for the non-compliance in question;and (2) the Signatory Consequences that are imposed will apply to it both inits capacity as an International Federation and in its capacity as a Major Event
Organization.
[Comment to Article 10.1.2.1: For example, if the Signatory is found to be non-compliant
with a High Priority requirement, then it will lose both the WADA Privileges it enjoys as
an International Federation and the WADA Privileges that it enjoys as a Major Event
Organization (Article B.2.1(a)), and there may be Supervision or Takeover by an
Approved Third Party of some or all of its Anti-Doping Activities both as an International
Federation and as a Major Event Organization (Article B.2.1(b)). In addition, if the
Signatory’s Representatives are ruled ineligible to sit on the boards or committees orPage 43 of 62other bodies of any Signatory or its members for a period (Article B.2.1(d)), thatconsequence will apply not only to the Representatives of the Signatory in its capacity
as an International Federation but also to the Representatives of the Signatory in its
capacity as a Major Event Organization].

10.1.2.2 Where the non-compliant Signatory is an ‘other organization with relevant
significance in sport’ (Code Article 23.1.1), it shall be subject to the Signatory
Consequences applicable to International Federations.
10.2 Principles Relevant to the Determination of the Signatory Consequences to be
Applied in a Particular Case
10.2.1 The Signatory Consequences applied in a particular case shall be proportionate to thenature and seriousness of the non-compliance in that case, taking into account both
the degree of fault of the Signatory and the potential impact of its non-compliance on
clean sport. As a guide to assessing the potential impact of a Signatory’s noncompliance on clean sport, the different requirements of the Code and International
Standards shall be categorized (in ascending order of gravity) as General, HighPriority, or Critical, as described further in Annex A. Where the case involves morethan one category of non-compliance, the Signatory Consequences imposed shall bebased on the gravest category of non-compliance. In terms of the degree of fault of
the Signatory, the obligation to comply is absolute, and so any alleged lack of intent orother fault is not a mitigating factor, but any fault or negligence on the part of a
Signatory may impact the Signatory Consequences imposed.
10.2.2 If there are Aggravating Factors in a particular case, that case shall attract significantly
greater Signatory Consequences than a case where there are no Aggravating Factors.
On the other hand, if a case includes extenuating circumstances, that may warrant theimposition of lesser Signatory Consequences.
10.2.3 Signatory Consequences shall be applied without improper discrimination between
different categories of Signatories. In particular, given that International Federations
and National Anti-Doping Organizations have equally important roles in fighting dopingin sport, they should be treated the same (mutatis mutandis) when it comes toimposing Signatory Consequences for non-compliance with their respective
obligations under the Code and the International Standards.
10.2.4 In accordance with the principle of proportionality referenced in Article 10.2.1, theSignatory Consequences imposed in a particular case shall go as far as is necessary
to achieve the objectives underlying the Code and this International Standard for CodeCompliance by Signatories. In particular, they shall be sufficient to motivate full CodeCompliance by the Signatory in question, to punish the Signatory’s non-compliance,
to deter further non-compliance by the Signatory in question and/or by other
Signatories, and to incentivize all Signatories to ensure they achieve and maintain fulland timely Code Compliance at all times.
10.2.5 Above all else, the Signatory Consequences imposed should be sufficient to maintainthe confidence of Athletes, other stakeholders, and of the public at large, in thecommitment of WADA and its partners from the public authorities and from the sport
movement to do what is necessary to defend the integrity of sport against the scourgeof doping. This is the most important and fundamental objective, overriding all others.
[Comment to Articles 10.2.4 and 10.2.5: As CAS ruled in ROC et al v IAAF, CAS 2016/O/4684

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and again in RPC v IPC, CAS 2016/A/4745, if a Signatory fails to deliver an Anti-Doping
Program that is compliant with the Code, then in order to restore a level playing field, to provide
a meaningful consequence that will provoke behavioral change within the Signatory’s sphereof influence, and to maintain public confidence in the integrity of International Events, it may benecessary (and therefore legitimate and proportionate) to go so far as to exclude the
Signatory’s affiliated Athletes and Athlete Support Personnel and/or its Representatives fromparticipation in those International Events.]

10.2.6 The Signatory Consequences should not go further than is necessary to achieve theobjectives underlying the Code. In particular, where a Signatory Consequence
imposed is the exclusion of Athletes and/or Athlete Support Personnel fromparticipation in one or more Events, consideration should be given to whether it isfeasible (logistically, practically, and otherwise) for other relevant Signatories to create
and implement a mechanism that enables the Athletes and/or Athlete Support
Personnel in question to demonstrate that they are not affected by the Signatory’s noncompliance. If so, and if it is clear that allowing them to compete in the Event(s) in aneutral capacity (i.e., not as representatives of any country) will not make the Signatory
Consequences that have been imposed less effective, or be unfair to their competitors
or undermine public confidence in the integrity of the Event(s) (e.g., because theAthletes have been subject to an adequate Testing regime for a sufficient period) or in
the commitment of WADA and its stakeholders to do what is necessary to defend theintegrity of sport against doping, then such a mechanism may be permitted, under thecontrol of and/or subject to the approval of WADA (to ensure adequacy andconsistency of treatment across different cases).
[Comment to Article 10.2.6: An example is the IAAF’s Competition Rule 22.1A, which (asdiscussed in ROC et al v IAAF, CAS 2016/O/4684) created the possibility for Athletes affiliatedto a suspended member national federation to apply for special eligibility to compete ininternational competitions as ‘neutral’ Athletes, where they could show that the suspended
member’s failure to enforce the anti-doping rules did not affect the Athlete in any way, because
he or she was subject to other, fully adequate anti-doping systems for a sufficiently long period
to provide substantial objective assurance of integrity. In particular, the Athlete had to showthat he or she had been subject to fully compliant Testing both in and out of competition thatwas equivalent in quality to the Testing to which his or her competitors in the international
competition(s) in question were subject in the relevant period.]10.2.7 The Signatory Consequences applied should include cessation of the Signatory’s noncompliant Anti-Doping Activities where necessary to maintain confidence in the
integrity of sport but should be designed to ensure as far as practicable that there is
no gap in the protection offered to clean Athletes while the Signatory is working tosatisfy the Reinstatement conditions. Depending on the circumstances of the particularcase, this may involve Supervision and/or Takeover of some or all of the Signatory’s
Anti-Doping Activities. Where the circumstances warrant, however, the Signatory may
be permitted to continue to conduct some or all Anti-Doping Activities (e.g., Education)
pending Reinstatement, provided this can be done without endangering clean sport.
In such circumstances, Special Monitoring of the activities in question may be
warranted.
10.2.8 Unless specified otherwise, all Signatory Consequences shall remain in effect only until
the Signatory is Reinstated. For the avoidance of doubt, however, nothing shall preventthe imposition of Signatory Consequences that apply (or continue to apply) after
Reinstatement, should the circumstances so warrant.
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[Comment to Article 10.2.8: The general rule is that all Signatory Consequences should cometo an end at the point when the Signatory is Reinstated. The exceptions are (a) where Annex B
specifies otherwise; and (b) where the facts and circumstances of the particular case make itappropriate (e.g., in order to ensure the punishment and/or the deterrent effect is adequate) forsome or all of the Consequences to remain in effect for a further (specified) period after
Reinstatement.]

10.2.9 The decision imposing the original Signatory Consequences (whether that decision is
the WADA proposal that is accepted by the Signatory or the CAS decision if the WADA
proposal is disputed by the Signatory) may specify that the Signatory Consequences
shall increase in the event that the Signatory does not satisfy all of the Reinstatement
conditions by a set deadline (in which case such increased or further Signatory
Consequences shall be specified in the original decision).
10.2.10 Applying the principles set out above, Annex B identifies the range of graded andproportionate Signatory Consequences that shall prima facie apply in cases involving
non-compliance with Critical requirements or only High Priority requirements or only
General requirements. The intention behind Annex B is to promote predictability andconsistency in the imposition of Signatory Consequences across all cases. However,there shall be flexibility to vary within or even to depart from this range in a particularcase, where the application of the principles set out above to the specific facts andcircumstances of that case so warrant. In particular, the greater the degree of noncompliance (i.e., the more requirements with which the Signatory has failed to comply,
and the more important those requirements are to clean sport), the greater the
Signatory Consequences should be.
11.0 Reinstatement
11.1 Objective
11.1.1 Once a Signatory has been determined to be non-compliant, the objective is to helpthat Signatory achieve Reinstatement as quickly as possible, while ensuring that
corrective actions have been taken that will deliver enduring Code Compliance by that
Signatory.
11.1.2 While WADA Management shall seek to guide the Signatory in its efforts to satisfy theReinstatement conditions as quickly as is reasonably practicable, that objective shallnot be allowed to compromise the integrity of the process and/or of the eventual
outcome.
11.2 Reinstatement Conditions
11.2.1 In accordance with Code Article 24.1.4, in the formal notice that it sends to the
Signatory, setting out the Signatory’s alleged non-compliance and the proposed
Signatory Consequences, WADA shall also specify the conditions that it proposes the
Signatory should have to satisfy in order to be Reinstated, which shall be as follows:
11.2.1.1 all of the matters that caused the Signatory to be declared non-compliant
shall have been corrected in full;
11.2.1.2 the Signatory shall have demonstrated that it is ready, willing, and able tocomply with all of its obligations under the Code and the International
Standards, including (without limitation) carrying out all of its Anti-Doping
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Activities independently and without improper outside interference. If further
Non-Conformities are identified after the Signatory has been declared noncompliant but before it is Reinstated, WADA will issue a new Corrective
Action Report in respect of those new Non-Conformities, and the normal
process and timeframes for correcting them (set out in Article 8) will apply,
but in addition the Signatory will not be Reinstated following the original
declaration of non-compliance unless and until it has corrected all of the new
Non-Conformities that relate to Critical or High Priority requirements;
11.2.1.3 the Signatory shall have respected and observed in full all of the Signatory
Consequences applied to it (save, for the avoidance of doubt, those Signatory
Consequences that are stated to apply, or to continue to apply, after
Reinstatement);
11.2.1.4 the Signatory shall have paid in full the following costs and expenses by thedeadline specified by WADA:(a)any specific costs and expenses (i.e., excluding costs and expenses
incurred as part of WADA’s routine monitoring activities) that werereasonably incurred by WADA in identifying the Signatory’s noncompliance (e.g., the costs of any specific investigation conducted by
WADA’s Intelligence and Investigations Department or any third party
contracted by WADA that identified such non-compliance);(b)

the costs and expenses reasonably incurred by WADA and/or
Approved Third Parties from the date on which the decision that the
Signatory was non-compliant became final until the date of the
Signatory’s Reinstatement, including (without limitation) costs andexpenses reasonably incurred in implementing the Signatory
Consequences (including the costs relating to Special Monitoring,
Supervision or Takeover and the costs of monitoring the Signatory’s
compliance with the Signatory Consequences) and the costs andexpenses reasonably incurred in assessing the Signatory’s efforts tosatisfy the Reinstatement conditions; and11.2.1.5 the Signatory shall have satisfied any other conditions that WADA’s
Executive Committee may specify (on the recommendation of the CRC)
based on the particular facts and circumstances of the case.
11.2.2 Within twenty-one (21) days of its receipt of the notice referenced in Code Article
24.1.4, in accordance with Code Article 24.1.6 the Signatory may dispute theReinstatement conditions proposed by WADA, in which case WADA will refer the caseto the CAS Ordinary Arbitration Division in accordance with Code Article 24.1.6 andCAS will determine whether all of the Reinstatement conditions proposed by WADA
are necessary and proportionate.
11.2.3 Subject to any contrary decision issued by CAS, to be eligible for Reinstatement a
non-compliant Signatory shall be required to demonstrate (by its own efforts but also
by securing the support and assistance of public authorities and/or other relevant
parties, as necessary) that it has satisfied each of the Reinstatement conditions
specified by WADA.
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11.2.4 WADA (and/or CAS) may establish an instalment plan for payment of the costs andexpenses set out in Article 11.2.1.4. In such a case, provided the Signatory is fully up
to date with payments under that instalment plan, once the Signatory has compliedwith all other Reinstatement conditions it may be Reinstated even if further instalments
will only become due for payment after the date of Reinstatement. However, theSignatory remains liable to pay all remaining instalments after such Reinstatement. A
failure to do so shall be processed as a new Non-Conformity with a High Priority
requirement.
11.3 The Reinstatement Process
11.3.1 WADA Management will monitor the Signatory’s efforts to satisfy the Reinstatement
conditions and will report to the CRC periodically on the Signatory’s progress. A
Compliance Audit and/or other compliance monitoring tools may be used to assist in
this task.
11.3.2 Where a Signatory’s right to conduct some or all Anti-Doping Activities has been
withdrawn, the CRC may recommend to WADA’s Executive Committee that the
Signatory be given back the right to conduct certain of those Anti-Doping Activities(under Special Monitoring and/or Supervision by an Approved Third Party) prior to full
Reinstatement. This recommendation will only be made where the CRC agrees with
WADA Management that the Signatory’s corrective efforts to date mean it is in aposition to implement such Anti-Doping Activities itself in a compliant manner.
11.3.3 Once WADA Management considers that the Signatory has met all of theReinstatement conditions, it will inform the CRC accordingly. If the CRC agrees with
WADA Management that the Signatory has met all of the Reinstatement conditions, itwill recommend that WADA’s Executive Committee confirm the Reinstatement of the
Signatory.
11.3.4 In accordance with Code Article 13.6, a decision by the CRC and/or WADA’s Executive
Committee that a Signatory has not yet met all of the conditions for its Reinstatement
may be appealed to CAS as provided in Article 9.6.
11.3.5 Only WADA’s Executive Committee has the authority to Reinstate a Signatory that has
been declared non-compliant.
11.3.6 WADA shall publish notice of the Signatory’s Reinstatement. Following the Signatory’s
Reinstatement, WADA shall monitor the Signatory’s Code Compliance closely for such
further period as it deems appropriate.
11.3.7 When it confirms such Reinstatement, WADA’s Executive Committee may impose
special conditions recommended by the CRC with which the Signatory shall comply
post-Reinstatement in order to demonstrate the Signatory’s continuing CodeCompliance, which may include (without limitation) conducting a Compliance Audit
within a specified period following Reinstatement. Any breach of such conditions shallbe processed in the same manner as any other new Non-Conformity.
12.0 Transitional Provisions
12.1 Proceedings Pending as of 1 April 2024
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12.1.1 Where a Corrective Action Report has been sent and/or a non-compliance procedure
has been commenced prior to 1 April 2024, but remains pending after 1 April 2024,
any procedural changes introduced by the revised version of this International
Standard approved on 16 November 2023 and 11 March 2024 will apply to that
pending Corrective Action Report and/or non-compliance procedure, but any
substantive changes introduced will not apply unless they are to the benefit of the
Signatory in question.

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ANNEX A: CATEGORIES OF NON-COMPLIANCE
The various different requirements imposed on Signatories by the Code and the International Standards
shall be classified either as General, or as High Priority, or as Critical, depending on their relative
importance to the fight against doping in sport. Examples of requirements in each of the three categories
are listed below. Requirements that are not listed below shall be classified into either the General or theHigh Priority category, reasoning by analogy from the examples listed below (i.e., requirements that areconsidered as important to the fight against doping in sport as the requirements that are listed below asHigh Priority requirements shall be categorized as High Priority, etc.). The classification shall be made in
the first instance by WADA Management, but the Signatory shall have the right to dispute theclassification, and the CRC and WADA’s Executive Committee (based on the CRC’s recommendation)
may take a different view. If the Signatory continues to dispute the classification, ultimately CAS will
decide.
A.1.

A.2.

The following is a non-exhaustive list of requirements that are considered to be General
requirements in the fight against doping in sport:a.

Tailoring Education activities that are specific to the needs of learners with impairments or
specific needs, in accordance with Article 5.5 of the International Standard for Education.

b.

Tailoring Education activities for learners who are Minors that are specific to their stage ofdevelopment and meet all applicable legal requirements, in accordance with Article 5.6 of theInternational Standard for Education.

c.

The establishment of a process to ensure that Athletes and other Persons do not breach theprohibition against participation while Ineligible or Provisionally Suspended, as described in
Code Article 10.14.

d.

In cases where it has been determined after a hearing or appeal that an Athlete or other
Person has not committed an anti-doping rule violation, using reasonable efforts to obtainthe consent of that Athlete or other Person to Publicly Disclose that decision, in accordancewith Code Article 14.3.4.

e.

Establishing a process designed to ensure that a Person is able to confirm in writing orverbally his/her understanding of the terms on which his/her Personal Information isprocessed, in accordance with Articles 6 and 7 of the International Standard for the Protectionof Privacy and Personal Information.

f.

Designating a Person within the Anti-Doping Organization who is accountable for compliancewith the International Standard for the Protection of Privacy and Personal Information and all
locally applicable privacy and data protection laws, in accordance with Article 4.5 of that
Standard.

The following is a non-exhaustive list of requirements that are considered to be High Priority
requirements in the fight against doping in sport:a.

The annual evaluation of the Education Program based on all available information and datathat is specifically related to the objectives in the Education Plan, in accordance with Article
6.2 of the International Standard for Education.
Page 50 of 62b.

The production of an annual evaluation report that informs the following year’s Education
Plan, in accordance with Articles 6.1 and 9.1(b) of the International Standard for Education.

c.

The training and authorizing of Educators responsible for delivering face-to-face education,
who are competent in Values-based Education and all topics in Code Article 18.2, in
accordance with Article 5.8 of the International Standard for Education.

d.

The establishment of a learning framework that identifies the learning objectives for eachtarget group in the Education Pool, in accordance with Article 5.4 of the International
Standard for Education (such as the example framework set out in chapter 5 of the Guidelines
to the International Standard for Education).

e.

The development of intelligence and investigation capabilities, as well as the use of thesecapabilities to pursue potential anti-doping rule violations, as required by Code Article 5.7
and in accordance with Articles 11 and 12 of the International Standard for Testing andInvestigations.

f.

The implementation of a documented procedure to ensure that Athletes (and/or a third party,
where the Athlete is a Minor) are notified that they are required to undergo Sample collectionin accordance with Article 5.4 of the International Standard for Testing and Investigations.

g.

The implementation of the requirements set out in Articles 7.4.5 to 7.4.7 of the International
Standard for Testing and Investigations for the documentation of the collection of a Sample
from an Athlete.

h.

The implementation of training/accreditation/re-accreditation programs for Sample Collection
Personnel in accordance with Article 5.3.2 and Annex G of the International Standard for
Testing and Investigations.

i.

The implementation of a conflict of interest policy in relation to the activities of the Sample
Collection Personnel, in accordance with Articles 5.3.2, G.4.2 and G.4.3 of the International
Standard for Testing and Investigations.

j.

The collection and processing of Samples in accordance with the requirements of Annexes
A to F and I of the International Standard for Testing and Investigations.

k.

The implementation of a Chain of Custody process for Samples in accordance with therequirements of Articles 8 and 9 of the International Standard for Testing and Investigations.

l.

The review of all Atypical Findings in accordance with Article 5.2 of the International Standard
for Results Management.

m. The timely notification to WADA and to the International Federation(s) and National AntiDoping Organization(s) of the subject(s) of the investigation into a potential anti-doping ruleviolation and the outcome of that investigation, in accordance with Article 12.3 of theInternational Standard for Testing and Investigations and the International Standard forResults Management.
n.

The reporting of all TUE decisions into ADAMS as soon as possible and in any event withintwenty-one (21) days of receipt of the decision, in accordance with Code Article 14.5.2 andArticle 5.5 of the International Standard for Therapeutic Use Exemptions.
Page 51 of 62

A.3.

o.

The publication of the outcome and required details of all cases within twenty (20) days ofthe decision being rendered, in accordance with Code Article 14.3.

p.

The requirement that an International Federation require as a condition of membership thatthe policies, rules and programs of its National Federations and other members are incompliance with the Code and International Standards, and take appropriate action to
enforce such compliance, in accordance with Code Articles 12 and 20.3.2.

q.

The requirement to pay (i) the costs of a WADA investigation, in accordance with Article
11.2.1.4(a); and/or (ii) Results Management costs in accordance with Code Article 7.1.5.

r.

The requirement for National Anti-Doping Organizations to be independent in theiroperational decisions and activities from sport and government, in accordance with Code
Article 20.5.1.

s.

The requirement for a Signatory, in accordance with Code Article 24.1.12.8(b), to ensure thatit has due authority under its statutes, rules and regulations, and/or under the relevant hosting
agreement(s), to withdraw from the grantee (whoever it may be) a previously-granted right tohost or co-host an International Event(s) in the country of a non-compliant National AntiDoping Organization or of a non-compliant National Olympic Committee acting as a National
Anti-Doping Organization.

The following is an exhaustive list of requirements that are considered to be Critical requirementsin the fight against doping in sport:a.

The adoption of rules, regulations, and/or (where necessary) legislation that satisfy the
Signatory’s obligation under Code Article 23.2 to implement the Code within the Signatory’s
sphere of responsibility.

b.

The satisfaction of the Signatory’s obligation under Code Article 23.3 to devote sufficient
resources in order to implement an Anti-Doping Program that is compliant with the Code andthe International Standards in all areas.
[Comment: To ensure an objective assessment, the implementation of this Criticalrequirement shall not be measured in isolation but rather through the successful
implementation by the Signatory of the other Code compliance requirements.]c.

The development and implementation of an effective Education Plan in accordance with Code
Article 18.2 and Article 4 of the International Standard for Education that seeks to implement
the principle that an Athlete should first experience the anti-doping effort via Education rather
than Testing.

d.

The provision of accurate and up to date information for Athletes and other Persons inaccordance with the topics identified in Code Article 18.2 and the International Standard for
Education, where possible by posting it on a conspicuous place on a website.

e.

The development and implementation of an effective, intelligent and proportionate Test
Distribution Plan in accordance with Code Article 5.4, based on the principles set out in Article
4 of the International Standard for Testing and Investigations, including in particular:
i. the development and application of a documented Risk Assessment;
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ii. the implementation of an effective Out-of-Competition Testing program, including(if applicable) the establishment and administration of a proportionate Registered
Testing Pool and one or more complementary Testing pools;iii. the implementation of Testing that is conducted in compliance with the TechnicalDocument for Sport Specific Analysis;
iv. No Advance Notice Testing;v. the use of an approved Athlete Passport Management Unit in accordance with
Annex C of the International Standard for Results Management; andvi. the implementation of an effective program for the Testing of Athletes prior to their
participation in the Olympic Games, the Paralympic Games, and/or other major
Events (including compliance with Article 4.8.12.5 (a) of the International Standard
for Testing and Investigations).
f.

The use of Sample Collection Equipment that meets the requirements of Article 6.3.4 of theInternational Standard for Testing and Investigations.

g.

The analysis of all Samples in accordance with Code Article 6.1.

h.

The timely transportation of Samples for analysis in accordance with Article 9.3.2 of theInternational Standard for Testing and Investigations.

i.

The adherence to the procedural requirements applicable to the analysis of B Samples(including, without limitation, giving the Athlete due notice of and an opportunity to attend at
the laboratory the opening and analysis of the B Sample) in accordance with Code Article
6.7, Article 5.3.4.5.4.8 of the International Standard for Laboratories, and Articles 5.1 and 5.2of the International Standard for Results Management.

j.

The entry of all Doping Control Forms into ADAMS within twenty-one (21) days of the dateof Sample collection, in accordance with Code Article 14.5.1 and Article 4.9.1(b) of theInternational Standard for Testing and Investigations.
[Comment: Entry of DCFs into ADAMS is classified as Critical due to the importance that timely entry
has on updating the Athlete Biological Passport in ADAMS, which may either result in an automatic
request to conduct IRMS analysis on a urine Sample or, following the review of a steroidal or blood
passport by an Athlete Passport Management Unit, require Target Testing of an Athlete or
retrospective analysis for substances (i.e. Erythropoiesis Stimulating Agents) that were not originallyanalyzed in the Sample.]k.

The appointment of a Therapeutic Use Exemption Committee, and a documented process
for Athletes to apply to that Therapeutic Use Exemption Committee for the grant or therecognition of a TUE, in accordance with the requirements of the International Standard for
Therapeutic Use Exemptions.

l.

The proper and timely pursuit of all Whereabouts Failures and potential anti-doping ruleviolations in accordance with Code Articles 7 and 8, including proper notification inaccordance with Code Article 7.2 and the International Standard for Results Management,
and provisions for a fair hearing within a reasonable time by a fair, impartial, and operationallyindependent hearing panel in accordance with Code Article 8.1.
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m. Without prejudice to the generality of Article A.3(k), (i) the requirement in Code Article 7.1.5
to conduct Results Management in a particular case in accordance with WADA’s directions;and (ii) where the Signatory does not comply with that requirement, the requirement in Code
Article 7.1.5 to reimburse the costs and attorney’s fees that another Anti-Doping Organization
designated by WADA incurs in conducting such Results Management.
n.

The notification of all relevant Results Management activities to WADA and to other AntiDoping Organizations in accordance with Code Articles 7.6 and 14 and the International
Standard for Results Management.

o.

The imposition of mandatory Provisional Suspensions in accordance with Code Article 7.4.1.

p.

The requirement to report on Code Compliance, in accordance with Code Articles 24.1.2 and24.1.3, including (without limitation) the requirement to respond to a Code Compliance
Questionnaire in accordance with Article 7.5, the requirement to respond to a Mandatory
Information Request in accordance with Article 7.6, and the requirement to submit to aCompliance Audit in accordance with Article 7.7.

q.

The recognition, implementation, and automatic binding effect of decisions determining antidoping rule violations that are rendered by other Signatories, a national arbitral body (CodeArticle 13.2.2) or CAS, in accordance with Code Article 15.1.

r.

The recognition and implementation of final decisions determining that other Signatories are
non-compliant, imposing consequences for such non-compliance, and/or setting conditions
that other Signatories have to satisfy in order to be Reinstated, rendered in accordance with
Code Article 24.1.9.

s.

The requirement for a Signatory, in accordance with Code Article 24.1.12.8(a), to withdraw
the hosting right referred to in Annex (s) above and re-assign the Event to another country,
unless the Signatory is able to demonstrate that it is legally and practically impossible to doso.

t.

The requirement for a non-compliant Signatory to satisfy any Signatory Consequences
imposed in accordance with Code Article 24.1 that fail to be satisfied post Reinstatement,
including (without limitation) paying any costs and expenses falling within Article 11.2.1.4 thathave been made the subject of an instalment payment plan in accordance with Article 11.2.4.

u.

Any requirement that is not already set out in the Code or the International Standards that
WADA’s Executive Committee exceptionally sees fit to impose as a Critical requirement.

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ANNEX B: SIGNATORY CONSEQUENCES
Annex B identifies the range of graded and proportionate Signatory Consequences that shall prima facie
apply in cases involving non-compliance with Critical requirements (see Article B.3) or only High Priority
requirements (see Article B.2) or only General requirements (see Article B.1). The intention is to promotepredictability and consistency in the imposition of Signatory Consequences across all cases. However,there shall be flexibility to vary within or even to depart from this range in a particular case, where theapplication of the principles set out in Article 10 to the specific facts and circumstances of that case so
warrant. In particular, the greater the degree of non-compliance (i.e., the more requirements with which
the Signatory has failed to comply, and the more serious those requirements), the greater the Signatory
Consequences should be. If a case includes not only non-compliance with one or more Criticalrequirements but also Aggravating Factors, that shall warrant a significant increase in the Signatory
Consequences imposed. On the other hand, if it includes extenuating circumstances, that may warrant theimposition of lesser Signatory Consequences.
In each case, the starting point shall be as follows:
B.1.

In a case of non-compliance with one or more General requirements (but not with any High Priority
or Critical requirements):
B.1.1. In the first instance:a.

the Signatory will lose its WADA Privileges;b.

it will be assisted in its Anti-Doping Activities (through the provision of advice andinformation, the development of resources, guidelines and training materials, and/or,
where necessary, the delivery of training programs) by WADA, or by an Approved
Third Party, at the Signatory’s expense, including up to two (2) visits a year, with all
known costs paid in advance; andc.

some or all of its Anti-Doping Activities (as specified by WADA) may be subject toeither Special Monitoring by WADA or Supervision by an Approved Third Party, at the
Signatory’s expense.

B.1.2. If the Signatory has not fully satisfied the conditions for Reinstatement twelve (12) months
after the Signatory Consequences set out at Article B.1.1 are imposed (or such otherperiod as WADA – or, if disputed, CAS – may specify), then the following further Signatory
Consequences will also apply:a.

some or all of the Signatory’s Anti-Doping Activities will be Supervised at the
Signatory’s expense by an Approved Third Party, including up to four (4) site visits ayear, with all known costs to be paid in advance (where known); andb.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any other Signatory (or its members) or association of
Signatories until the non-compliant Signatory is Reinstated.

B.1.3. If the Signatory has still not fully satisfied the conditions for Reinstatement twenty-four (24)months after the Signatory Consequences set out at Article B.1.1 are imposed (or suchother period as WADA – or, if disputed, CAS – may specify), then the following further
Page 55 of 62

Signatory Consequences will also apply:

B.2.

a.

all of the Signatory’s Anti-Doping Activities will be Supervised by an Approved Third
Party, at the Signatory’s expense, including up to six (6) site visits a year, with all
known costs to be paid in advance (where known);b.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any Signatory (or its members) or association of
Signatories until the non-compliant Signatory is Reinstated or for one (1) year
(whichever is longer); andc.

(if the Signatory is an organization outside of the Olympic Movement and Paralympic
Movement, not recognized by the International Olympic Committee and not a memberof or recognized by the International Paralympic Committee, and maintains its
Signatory status under the applicable WADA policy) the Signatory’s status as a
Signatory to the Code will be terminated, without any entitlement to reimbursementof any fees paid for such status.

In a case of non-compliance with one or more High Priority requirements (but not with any Criticalrequirements):
B.2.1. In the first instance:a.

the Signatory will lose its WADA Privileges;b.

some or all of its Anti-Doping Activities (as specified by WADA) will be subject toSupervision or Takeover by an Approved Third Party, at the Signatory's expense,
including up to six (6) site visits a year, with all costs paid in advance (where known);c.

the Signatory may be required to pay a Fine;d.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any Signatory (or its members) or association of
Signatories until the non-compliant Signatory is Reinstated;e.

(where the Signatory is a National Anti-Doping Organization or a National Olympic
Committee acting as a National Anti-Doping Organization) the Signatory’s country
may not be awarded the right to host regional, continental or world championships,
or other International Events, including the Olympic Games and/or the Paralympic
Games, until the Signatory is Reinstated;f.

(if the Signatory is an International Federation) the Signatory will have any funding
and other benefits of the recognition by the International Olympic Committee or themembership of the International Paralympic Committee or of recognition by ormembership of any other Signatory suspended until the Signatory is Reinstated; andg.

(if the Signatory is a Major Event Organization) there will be Special Monitoring or
Supervision or Takeover of its Anti-Doping Program by an Approved Third Party, atthe Signatory’s expense, at the next edition of the Signatory’s Event prior toReinstatement.

B.2.2. If the Signatory has not fully satisfied the conditions for Reinstatement twelve (12) months
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after the Signatory Consequences set out at Article B.2.1 are imposed (or such otherperiod as WADA – or, if disputed, CAS – may specify), then the following further Signatory
Consequences will also apply:a.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any Signatory (or its members) or association of
Signatories until the non-compliant Signatory is Reinstated or for two (2) years(whichever is longer);b.

the Signatory will be required to pay a further Fine;c.

(where the Signatory is a National Anti-Doping Organization or a National Olympic
Committee acting as a National Anti-Doping Organization) the Representatives of the
National Olympic Committee and National Paralympic Committee of the Signatory’s
country will, until Reinstatement, be excluded from participation in or attendance atregional and/or continental championships and/or world championships and/or the
Olympic Games and Paralympic Games;d.

(where the Signatory is an International Federation):

e.

f.

1.

the Signatory will be ineligible to receive funding or enjoy any of the other benefitsof recognition by the International Olympic Committee or of membership of theInternational Paralympic Committee or of recognition by or membership of any
other Signatory until the Signatory is Reinstated (and then it shall still not be able
to receive any funding or other benefits retrospectively for the period of noncompliance prior to Reinstatement); and2.

until Reinstatement, the Signatory’s Representatives will be excluded fromparticipation in or attendance at the regional and/or continental multi-sport
Events and/or the Olympic Games and Paralympic Games;(where the Signatory is a Major Event Organization):1.

the Signatory will have any funding and/or other benefits of recognition by theInternational Olympic Committee or membership of the International Paralympic
Committee or recognition by or membership of any other Signatory suspended
until it is Reinstated (and then it shall still not be able to receive any funding orother benefits retrospectively for the period prior to Reinstatement); and2.

the Signatory’s forthcoming Event(s) taking place prior to Reinstatement will not
be treated as a qualifying event(s) for the Olympic Games or Paralympic Games;and(where the Signatory is an organization outside of the Olympic Movement andParalympic Movement, not recognized by the International Olympic Committee andnot a member of or recognized by the International Paralympic Committee, andmaintains its Signatory status under the applicable WADA policy) the Signatory’s
status as a Signatory to the Code will be terminated, without any entitlement toreimbursement of any fees paid for such status.

B.2.3. If the Signatory has not fully satisfied the conditions for Reinstatement twenty-four (24)months after the Signatory Consequences set out at Article B.2.1 are imposed (or such
Page 57 of 62other period as WADA – or, if disputed, CAS – may specify), then the following further
Signatory Consequences will also apply:

B.3.

a.

(where the Signatory is a National Anti-Doping Organization or a National Olympic
Committee acting as a National Anti-Doping Organization) the Athletes and Athlete
Support Personnel representing that country or representing the National Olympic
Committee, National Paralympic Committee, or National Federation of that country
will, until Reinstatement, be excluded (subject to Article 10.2.6) from participation in
or attendance at the Olympic Games and Paralympic Games and/or world
championships and/or regional and/or continental championships; andb.

(where the Signatory is an International Federation) the Athletes and Athlete Support
Personnel participating in the Signatory’s sport (or in one or more disciplines of thatsport) will, until Reinstatement, be excluded from participation in or attendance at the
Olympic Games and Paralympic Games and/or any other multi-sport Event.

In a case of non-compliance with one or more Critical requirements:
B.3.1. In the first instance:a.

the Signatory will lose its WADA Privileges;b.

the Signatory will be required to pay a Fine;c.

some or all of its Anti-Doping Activities (as specified by WADA) will be subject toSupervision or Takeover by an Approved Third Party, at the Signatory’s expense,
including up to six (6) site visits a year, with all costs to be paid in advance (where
known);

d.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any Signatory (or its members) or association of
Signatories until the Signatory is Reinstated or for one (1) year (whichever is longer);e.

(where the non-compliant Signatory is a National Anti-Doping Organization or a
National Olympic Committee acting as a National Anti-Doping Organization):1.

for a specified period, no other Signatory will (i) organize or sanction or recognize
or otherwise associate itself or allow itself to be associated with any regional,
continental or world championships, or other International Events, in the noncompliant Signatory’s country, or (ii) permit any of its members to do so; and/or

2.

for the same or a different period, no other Signatory will award anyone (or permit
any of its members to award anyone) the right to host in the non-compliant
Signatory’s country any future edition(s) of regional, continental, or world
championships, or other International Events;

3.

Major Event Organizations will not permit the country’s flag to be displayed at orin association with, and will exclude the Representatives of the National Olympic
Committee and National Paralympic Committee of the Signatory’s country
from participation in or attendance at, and (subject to Article 10.2.6) will exclude
the Athletes and Athlete Support Personnel representing that country (orrepresenting the National Olympic Committee, National Paralympic Committee,
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or National Federation of that country) from participation in or attendance at,regional, continental or world championships, or other International Events,organized by those Major Event Organizations (excluding, for the avoidance of
doubt the Olympic Games and Paralympic Games), in each case until
Reinstatement; and
4.

f.

g.

h.

the International Olympic Committee (in respect of the Olympic Games) and theInternational Paralympic Committee (in respect of the Paralympic Games) will
not permit the country’s flag to be displayed or to appear at or in association with,and will exclude the Representatives of the National Olympic Committee andNational Paralympic Committee of the non-compliant Signatory’s country fromparticipation in or attendance at, the Olympic Games and Paralympic Games,
until Reinstatement;(where the Signatory is an International Federation):1.

the Signatory’s Representatives will be excluded from participation in or
attendance at, and the Athletes and Athlete Support Personnel participating in
the Signatory’s sport (or in one or more disciplines of that sport) may be excluded
from participation in or attendance at, regional, continental or international multisport Events organized by Major Event Organizations (excluding, for the
avoidance of doubt, the Olympic Games and Paralympic Games) in each caseuntil Reinstatement; and2.

the Signatory’s Representatives will be excluded from participation in or
attendance at the Olympic Games and Paralympic Games and/or any othermulti-sports Event until Reinstatement;(where the Signatory is a Major Event Organization):1.

there will be Supervision or Takeover of some or all of the Signatory’s AntiDoping Program at the Signatory’s expense at its Events until Reinstatement;
and2.

the Signatory will be ineligible to receive some or all funding or enjoy any of theother benefits of recognition by the International Olympic Committee or themembership of the International Paralympic Committee or recognition by ormembership of any other Signatory until it is Reinstated (and then it shall still not
be permitted to receive any funding or other benefits retrospectively for the periodprior to Reinstatement); and(where the Signatory is an organization outside of the Olympic Movement andParalympic Movement, not recognized by the International Olympic Committee andnot a member of or recognized by the International Paralympic Committee, andmaintains its Signatory status under the applicable WADA policy) the Signatory’s
status as a Signatory to the Code will be terminated, without any entitlement toreimbursement of any fees paid for such status.

B.3.2. If the Signatory has not satisfied the conditions for Reinstatement twelve (12) months after
the Signatory Consequences set out in Article B.3.1 are imposed (or such other period as
WADA – or, if disputed, CAS – may specify), then the following further Signatory
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Consequences will also apply:a.

the Signatory’s Representatives will be ineligible to sit as members of the boards orcommittees or other bodies of any Signatory (or its members) or association of
Signatories until the non-compliant Signatory is Reinstated or for four (4) years(whichever is longer);b.

(where the Signatory is a National Anti-Doping Organization or a National Olympic
Committee acting as a National Anti-Doping Organization):

c.

d.

1.

the Signatory’s country may not host regional, continental, or world
championships, or other International Events and/or the Olympic Games and/or
the Paralympic Games for a specified period; and2.

(subject to Article 10.2.6) the Athletes and Athlete Support Personnel
representing that country (or representing the National Olympic Committee,
National Paralympic Committee, or National Federation of that country) will, until
the Signatory’s Reinstatement, be excluded from participation in or attendanceat (if it is not already the case pursuant to Article B.3.1) regional, continental orworld championships, or other International Events, including the Olympic
Games and Paralympic Games;(where the Signatory is an International Federation):1.

the Athletes and Athlete Support Personnel participating in the Signatory’s sport(or in one or more disciplines of that sport) will be excluded from participation in
or attendance at the Olympic Games and Paralympic Games until
Reinstatement; and2.

the Signatory will be ineligible to receive funding or enjoy any of the other benefitsof recognition by the International Olympic Committee or of membership of theInternational Paralympic Committee or of recognition by or membership of any
other Signatory until it is Reinstated (and then it shall still not be able to receive
any funding retrospectively for the period prior to Reinstatement);(where the Signatory is a Major Event Organization):1.

the Signatory will be ineligible to receive funding or enjoy any of the other benefitsof recognition by the International Olympic Committee or the membership of theInternational Paralympic Committee or recognition by or membership of any
other Signatory until it is Reinstated (and then it shall still not be able to receive
any funding or other benefits retrospectively for the period prior toReinstatement); and2.

the status of the Signatory’s Event(s) as a qualifying event for the Olympic
Games or Paralympic Games will be lost;e.

the Signatory will be required to pay a further Fine; andf.

a recommendation may be made to the relevant public authorities to withhold some or
all public and/or other funding and/or other benefits from the Signatory for a specified
period (with or without the right to receive such funding and/or other benefits for that
Page 60 of 62

period retrospectively following Reinstatement).
B.3.3. If the Signatory has not satisfied the conditions for Reinstatement twenty-four (24) months
after the Signatory Consequences set out in Article B.3.1 are imposed (or such otherperiod as WADA – or, if disputed, CAS – may specify), then the following further Signatory
Consequence will also apply: suspension of recognition by the Olympic Movement and/or
as a member of the Paralympic Movement and/or of recognition by/membership of any
other Signatory, as applicable.
B.4.

Where Signatory Consequences set out in this Annex B apply to the Representatives of a National
Anti-Doping Organization (or of a National Olympic Committee acting as a National Anti-Doping
Organization), then (as per the Code definition of Representatives) they apply not only to theofficials, directors, officers, elected members, employees, and committee members of that National
Anti-Doping Organization/National Olympic Committee but also to the state representatives of thecountry of that National Anti-Doping Organization/National Olympic Committee. For purposes ofapplication of the Consequences set out in this Annex B, such state representatives shall include(without limitation) any person falling within one or more of the following categories (i) at the time
the Consequences are imposed; and/or (ii) at any time during the period when the non-compliance
took place for which the Consequences have been imposed (provided that the Consequences may
be limited to apply only to certain such persons, where broader application would be
disproportionate):a. members of the executive branch, legislative branch, and/or judicial branch of the country’s
national government (e.g. federal, unitary, monarchy), whatever their title:
1. heads of state;
2. the President, any members of the office of the President, and any other person working
for or on behalf of the President or the office of the President;
3. Vice-President(s);4. Prime Ministers and Deputy Prime Ministers;
5. members of the cabinet, secretaries of state, and ministers and deputy ministers;
6. senior members of the civil service, including (without limitation) heads and deputy
heads of government agencies or other constituent bodies or organs of the relevant
national government; assistants/advisors to such persons; specialists providing
specialist support to such persons; and all civil servants with diplomatic status.
7. heads and deputy heads of any state-run sports bodies, centres, or programmesorganised under the authority of the national government;
8. members of any monarchy;
9. members of any body with official legislative or regulatory authority (however styled,e.g., Parliament/Congress/National Assembly or similar) or of any division (e.g. different
houses) of that body; and10. judges of any state courts (whether federal, regional, or local);Page 61 of 62

b. members of government security agencies;
c. members of any state investigative authorities;
d. officers of the rank of captain or above of the military/armed forces; ande. officers of the rank of captain or above in any police force(s);provided always that (1) any Athlete or Athlete Support Personnel who would fall within any ofthese categories is excluded from the definition with respect to a given sports event or competition,
if they are seeking to attend or participate in that event or competition solely in their capacity as
Athlete or Athlete Support Personnel and not in any way in their capacity as a representative of thestate; (2) persons who are appointed as International Olympic Committee and/or International
Paralympic Committee members in their personal capacities are excluded from the definition; and(3) persons who are invited to specified events by Heads of State or Prime Ministers of hostcountries are excluded from the definition.

Page 62 of 62