TheIndependent Context Assessment Prepared for the Saudi Arabian Football Federation in relation to the FIFA World Cup 2034 can be found on FIFA’s website. FIFA’s Human Rights Policy, adopted in 2017, outlines its responsibility to identify and address adverse human rights impacts of its operations, including taking adequate measures to prevent and mitigate human rights abuses

A flawed human rights assessment of Saudi Arabia’s FIFA 2034 World Cup bid by AS&H Clifford Chance – part of the global partnership of London-based law firm Clifford Chance – leaves the global firm at risk of being linked to abuses which result from the tournament, 11 organisations said today.

AS&H Clifford Chance, which is based in Riyadh and sits within Clifford Chance’s integrated global partnership, produced an “independent human rights context assessment” that was published by FIFA and which has helped pave the way for Saudi Arabia to be confirmed as 2034 hosts on 11 December, as is widely expected to happen. The assessment contains no substantive discussion of extensive and relevant abuses in Saudi Arabia documented by multiple human rights organisations and UN bodies. It formed the basis of Saudi Arabia’s human rights strategy for the tournament, which was described by Amnesty International as a “whitewash”.

“It has been clear for more than a year now that FIFA is determined to remove all potential obstacles to make sure it can hand Saudi Arabia’s Crown Prince Mohammed bin Salman the 2034 World Cup.”

James Lynch, Co-director of FairSquare

The 11 organisations, which include a Saudi Arabian diaspora organisation, Gulf human rights groups, and labour organisations, as well as Football Supporters Europe, Amnesty International and Human Rights Watch, wrote to Clifford Chance’s Global Managing Partner, setting out in detail all the concerns in this statement, and inviting the authors to publish an updated report. The firm, which says that it works in partnership with “some of the world’s leading NGOs and civil society organisations”, said in response last week that it would be “inappropriate” to offer any further comment on the report and shared a link to publicly available company policies.

“AS&H Clifford Chance had the chance to write a credible assessment of risks that are relevant to the 2034 World Cup. Instead they have produced an artificially limited, misleading and overly positive perspective.” 

Julia Legner, Executive Director of ALQST for Human Rights

“It has been clear for more than a year now that FIFA is determined to remove all potential obstacles to make sure it can hand Saudi Arabia’s Crown Prince Mohammed bin Salman the 2034 World Cup,” said James Lynch, co-director of the FairSquare human rights organisation, which led the joint approach to the law firm. “By producing a shockingly poor report, AS&H Clifford Chance, part of one of the world’s largest law firms that makes much of its human rights expertise, has helped to remove a key final stumbling block.”

Saudi Arabia’s already dire human rights record has deteriorated under the de facto rule of Crown Prince Mohammed bin Salman, who has presided over a soaring number of mass executions, torture, enforced disappearance, severe restrictions on free expression, repression of women’s rights under the male guardianship system, LGBTI+ discrimination, and the killing of hundreds of migrants at the  Saudi Arabia-Yemen border. The country’s abusive Kafala (labour sponsorship) system, as well as the prohibition on trade unions and lack of enforcement of labour laws continues to lead to the widespread exploitation of migrant workers.

The 11 organisations warned Clifford Chance that, through the production of its human rights assessment by AS&H Clifford Chance, there is a risk that the firm could be linked to potential adverse human rights impacts resulting from a Saudi Arabia-hosted tournament.

“AS&H Clifford Chance had the chance to write a credible assessment of risks that are relevant to the 2034 World Cup. Instead they have produced an artificially limited, misleading and overly positive perspective, that serves only to whitewash the reality of abuse and discrimination faced by Saudi Arabia’s citizens and residents,” said Julia Legner, Executive Director of ALQST for Human Rights, a Saudi Arabian diaspora organisation.

“The severe risks of hosting the 2034 World Cup in Saudi Arabia are clear and well-known – without huge reforms, critics will be arrested, women and LGBT people will face discrimination, and workers will be exploited on a massive scale.”

Steve Cockburn, Head of Labour Rights and Sport at Amnesty International.

In their memorandum to Clifford Chance, the organisations set out, and requested comment on, three overarching concerns about the assessment. Taken together, these fatally undermine the report’s claim to provide an independent assessment of the human rights context in Saudi Arabia, relevant to the hosting and staging of the 2034 World Cup.

• AS&H Clifford Chance agreed to a decision by FIFA and the Saudi Arabian Football Federation (SAFF) to effectively exclude analysis of Saudi Arabia’s record on multiple critical human rights such as freedom of expression, LGBTI+ discrimination, the prohibition of trade unions, or forced evictions – either because Saudi Arabia has not ratified the relevant treaties or because SAFF did not accept them as “applying”. Any assessment that does not recognise these as relevant human rights risks for a World Cup in Saudi Arabia cannot be considered credible.

• The assessment made highly selective use of the findings of UN bodies on Saudi Arabia, leaving out damaging judgements. For example, it fails to reference one UN body’s concern at receiving reports that “torture and other ill-treatment are commonly practised in prisons”, or another which notes that “women and girls who are victims of sexual abuse risk facing criminal proceedings if they press charges”. It does not mention that Saudi Arabia is currently facing a labour complaint at the UN brought by Building and Woodworkers International, an international trade union. No reports by UN Special Rapporteurs are included, meaning for example that there is no reference to the imposition of the death penalty in relation to the Crown Prince’s flagship giga-project Neom, nor the murder of Saudi Arabian journalist Jamal Khashoggi.

• There is no evidence that AS&H Clifford Chance consulted external experts, such as people who might be affected by human rights abuses linked to the tournament, Saudi Arabian human rights experts or organisations, international human rights organisations, or trade unions. No work by such groups is referenced. The report, for example, ignores Amnesty International’s 2024 91-page report Playing a Dangerous Game? Human Rights Risks Linked to the 2030 and 2034 FIFA World Cups.

“The severe risks of hosting the 2034 World Cup in Saudi Arabia are clear and well-known – without huge reforms, critics will be arrested, women and LGBT people will face discrimination, and workers will be exploited on a massive scale”, said Steve Cockburn, Head of Labour Rights and Sport at Amnesty International.

“It is incredible that AS&H Clifford Chance omitted such glaring risks from its assessment and scandalous that FIFA paved the way for them to do so. FIFA must now insist on a proper assessment and meaningful human rights strategy, or its flagship tournament will inevitably be tarnished by severe human rights violations.”

Amnesty International has written to FIFA asking it to confirm on what basis the organisation agreed with the Saudi Arabian Football Federation to limit the scope of the rights assessment conducted by AS&H Clifford Chance. As at 25 October, FIFA had not responded.

“The hundreds of thousands of people expected to arrive in Saudi Arabia to build stadiums and clean hotels ahead of the World Cup are at great risk of severe exploitation and even death. How can these realities have escaped AS&H Clifford Chance’s attention?”

Martha Waithira, Equidem Investigator, and former domestic worker in Saudi Arabia

“As a former domestic worker in Saudi Arabia from Kenya, I know that women like me are often treated like slaves. Women especially face sexual and other gender abuse. I’m in regular contact with workers in horrific situations in Saudi Arabia,” said Equidem investigator Martha Waithira. “Now, the hundreds of thousands of people expected to arrive in Saudi Arabia to build stadiums and clean hotels ahead of the World Cup are at great risk of severe exploitation and even death. How can these realities have escaped AS&H Clifford Chance’s attention?”

The full list of signatories:

FairSquare, ALQST for Human Rights, Amnesty International, The Army of Survivors, Building and Woodworkers International, Equidem, Football Supporters Europe, Gulf Centre for Human Rights, Human Rights Watch, Middle East Democracy Center, Migrant-Rights.org

Background

TheIndependent Context Assessment Prepared for the Saudi Arabian Football Federation in relation to the FIFA World Cup 2034 can be found on FIFA’s website. FIFA’s Human Rights Policy, adopted in 2017, outlines its responsibility to identify and address adverse human rights impacts of its operations, including taking adequate measures to prevent and mitigate human rights abuses.

Clifford Chance is one of the world’s largest law firms. It has made multiple commitments concerning its human rights responsibilities, including in its company code. The firm states on its global website that its client base in Saudi Arabia, delivered “through AS&H Clifford Chance” includes “key Saudi Ministries and government-owned entities as well as a wide range of government owned, privately and publicly held Saudi and international businesses, listed companies and financial institutions.” These Saudi clients include the Public Investment Fund. AS&H Clifford Chance is a Joint Venture (JV) between Clifford Chance and AS&H that has been registered in Saudi Arabia since 2023. It is integrated within Clifford Chance’s global firm, “follows [the global firm’s] processes and practices”, and employs a number of Clifford Chance partners, including a “Senior Clifford Chance partner”. The Independent Context Assessment refers readers to the global Clifford Chance website.