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THE EUROPEAN TOUR INTEGRITY PROGRAMME
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THE EUROPEAN TOUR INTEGRITY PROGRAMME

SECTION 1. Policy

1. Application and Scope of Policy

a) All Covered Persons shall be bound by and comply with all of the provisions set out in the ETIP and honour the declaration for “Integrity in Golf”:

“All Members, Players, Related Personnel and Employees of the PGAET must act with honesty and sportsmanship at all times so that we represent the honour and dignity of fair play and preserve the recognised high standards associated with Integrity in Golf”.

b) The PGAET has appointed a person who will be primarily responsible for integrity related issues at the PGAET. That person will be referred to as the European Tour Integrity Officer (“ETIO”). In relation to any alleged breach of the Policy, the ETIO in conjunction with the IGF shall be responsible for the selection of the Investigation Unit, will review the findings and recommendations of each such investigation and shall determine whether there is sufficient evidence to warrant the relevant individuals being subject to a Disciplinary Procedure.

1.1 Application of Policy

a) This Policy is made by the PGAET and is binding on all Covered Persons, who shall be deemed to accept all the terms set out herein as follows:

(i) in the case of Members, acceptance of the terms of the Policy is incorporated into the European Tour Members Regulations;

(ii) in the case of Players, acceptance of the terms of the Policy is incorporated into the terms and conditions for participation in a PGAET Sanctioned Tournament;

(iii) in the case of Related Personnel, acceptance of the terms of the Policy is incorporated into the terms and conditions in their accreditation or permission to access a golf course at a PGAET Sanctioned Tournament; and

(iv) in the case of Employees of the PGAET, acceptance of the terms of the Policy is incorporated into the European Tour Employment.

b) It is the responsibility of each Covered Person to acquaint himself or herself with all of the provisions of the ETIP (including the Regulations and procedures set out below).

c) Additionally, each Player will have a duty to inform his Related Personnel about all the relevant provisions of the ETIP and instruct each of them to comply with all such relevant provisions including the Regulations.

d) Any Covered Person who is alleged to have breached the Regulations shall be subject to the procedures and possible sanctions set out in this Policy and those persons should also be aware that conduct prohibited under this Policy may also constitute a criminal offence and/or breach of other applicable laws and regulations.

e) This Policy may be amended from time to time by the PGAET.

f) The PGAET may, in its sole discretion, delegate any or all of its powers under this Policy, including but not limited to the power to apply, monitor and enforce this Policy.

g) This Policy came into effect on 23 November 2015.

1.2 Scope of Policy

a) Golf Tournaments

This Policy is binding on all Covered Persons in relation to any professional or elite amateur golf event (or any part thereof) that is staged anywhere in the world, with the exception of an IGF Governed Event. Notwithstanding the above, for a Player who is not a Member and his Related Personnel, this Policy shall only be binding with regards to his participation in any PGAET Sanctioned Tournament.

b) IGF Governed Event

If a Covered Person is alleged to have committed a breach of the IGF Policy during an IGF Governed Event, then the IGF will conduct its own investigation following the procedures set out in the IGF Policy. The PGAET and its Members will accept any decision or sanction made by the IGF in relation to any Covered Person under the IGF Policy.

2. Education

a) Each Member will be required to complete the Education Course which will involve an informational presentation and a short test. This is a mandatory test and each Member must complete and pass it as a requirement of his membership conditions as set out in the annual membership form.

b) Each Member must personally complete the Education Course. Any Member found to have had another party complete it for him will be required to personally complete the Education Course and may be liable to sanction under the PGAET’s Code of Behaviour and Disciplinary Procedure.

c) The Education Course only has to be completed once by each Member, unless otherwise determined by the PGAET.

d) Notwithstanding Section 2(c) above all Covered Persons shall regularly review the Policy and read any notifications they receive from the PGAET regarding any amendments to the Policy.

3. Regulations

a) Corruption Offences

(i) No Covered Person shall either directly or indirectly bet or instruct any other person to bet on the result, progress, conduct or any other aspect of any professional or elite amateur golf event (or any part thereof) anywhere in the world.

(ii) No Covered Person shall, directly or indirectly, solicit or facilitate any other person to bet on the outcome or any other aspect of any professional or elite amateur golf event (or any part thereof) anywhere in the world. For the avoidance of doubt, to solicit or facilitate to bet shall include displaying live golf betting odds on the website or social media platform of a Covered Person.

(iii) No Member or Player shall have any financial interest, either direct or indirect, in the performance or winnings of any Other Player whether through purse-splitting, prize money “insurance”, financial assistance, bets or otherwise.

(iv) No Covered Person shall directly or indirectly provide, offer, give, request or receive any money, benefit or consideration in circumstances that the Covered Person might reasonably have expected could bring him, the PGAET or the sport of golf into disrepute.

(v) A Member or Player shall not fail to give his best efforts, and a Covered Person shall not either directly or indirectly induce or encourage any Other Player to fail to give his best efforts, in any professional or elite amateur golf event (or any part thereof) anywhere in the world.

(vi) No Covered Person shall directly or indirectly use or provide to any other person any information relating to any aspect of any professional or elite amateur golf event (or any part thereof) anywhere in the world, which they have by virtue of their position within the game and which is not publicly available and which information could reasonably be anticipated to be used for, or in relation to, betting.

(vii) No Covered Person shall directly or indirectly contrive or attempt to contrive any aspect of any professional or elite amateur golf event (or any part thereof) anywhere in the world.

(viii) Each Member and Player shall be responsible (to the extent that it is reasonably possible for him to be so) for any actions of his Related Personnel. Therefore any proven breach of those Regulations by such “Related Personnel” shall be considered as a breach of these Regulations by the Member or Player himself.

(ix) If a Covered Person knowingly assists or is a party to ‘covering up’ conduct which is prohibited by these Regulations, that Covered Person will be treated as having engaged in such conduct personally.

b) Reporting Obligations

(i) Any Covered Person shall inform the ETIO immediately, on a confidential basis, of any incident or activity, including approaches from any person or third party, which he/she believes may or will contravene or may or will lead to the contravention of the ETIP.

(ii) In the event that any Covered Person is approached by any person who offers or provides any type of money, benefit or consideration to that Covered Person to (i) influence the outcome or any other aspect of any professional or elite amateur golf event (or any part thereof) anywhere in the world, or (ii) provide information as described in Section 3(a)(vi) above, it shall be the Covered Person’s obligation to report such incident to the ETIO and/or the PGAET as soon as possible.

(iii) Any attempt by a Covered Person, or any agreement by a Covered Person with any other person, to engage in conduct that would culminate in the breach of any of the Regulations shall be treated as if a breach of the Regulations has been committed, whether or not such attempt or agreement in fact resulted in such breach of the Regulations. However, there shall be no breach of the Regulations under this Regulation where the Covered Person renounces his attempt or agreement prior to it being discovered by a third party not involved in the attempt or agreement.

(iv) Any Covered Person shall provide the ETIO, the PGAET or the Investigation Unit with full access to and copies of any documents or information which the ETIO, the PGAET or the Investigation Unit requests if a breach of the ETIP has been alleged to have occurred and shall cooperate in full with any investigation and/or any disciplinary procedure that is carried out in relation to an alleged breach of these Regulations.

c) For a breach of these Regulations to be committed, it is sufficient that an offer or enticement was made, regardless of whether any money, benefit or consideration was actually paid or received.

d) Any alleged breach of these Regulations shall initially be subject to the investigations procedure set out in Section 4(b) below and may be subject to a Disciplinary Procedure.

4. Procedures

a) IBIS and Whistleblowing

(i) Through the PGAET’s relationship with the IGF, PGAET Sanctioned Tournaments will be monitored by IBIS. This system involves direct information sharing with betting regulators, betting operators and Interpol.

(ii) If any Covered Person is identified by IBIS for any betting irregularities during a PGAET Sanctioned Tournament, IBIS will inform the Executive Director of the IGF, who will refer the breach to the ETIO. The PGAET will then conduct an investigation in accordance with the procedures set out in Section 4(b) below.

(iii) If a Covered Person or any other person wishes to report an incident that may potentially be a breach of the ETIP, he or she must contact the ETIO. If the ETIO considers it necessary, the ETIO will take the necessary steps to procure that an investigation into the incident and the alleged breach of the Regulations takes place in accordance with Section 4(b) below.

(iv) Upon receiving a report of a potential breach of the ETIP in accordance with Section 4(a)(iii) above, the ETIO will inform the Chief Executive Officer of the PGAET and the Executive Director of the IGF or another representative of the IGF.

(v) For the purposes of applicable data and other laws and for all other purposes, each Covered Person consents to the collection, processing, disclosure and use of information relating to him and his activities, including personal information relating to him and his activities, to the extent expressly permitted under the terms of the ETIP (and that he shall confirm such agreement in writing upon demand).

b) Investigations

(i) After the ETIO has communicated with the IGF, the ETIO will appoint an Investigation Unit to carry out the investigation as to whether there has been a potential breach of the Regulations. The ETIO will choose the Investigation Unit from a pool of consultants proposed by the IGF.

(ii) Once the Investigation Unit has been appointed, the ETIO will issue an official notice to the Covered Person(s) (as appropriate) who is or are the subject of the investigation under the ETIP.

(iii) The investigation must be conducted in a transparent, discreet and fair manner.

(iv) The Investigation Unit must report its findings and provide any recommendations to the ETIO so that the ETIO can determine whether there is sufficient evidence to warrant the relevant individuals being subject to a Disciplinary Procedure.

c) Determination of evidence and recommendations

(i) After the Investigation Unit has conducted an investigation and submitted its findings to the ETIO, the ETIO will determine whether there is sufficient evidence to warrant the relevant individuals being subject to a Disciplinary Procedure based on the following factors:

· The evidence and findings reported from the investigation.

· The recommendations made by the Investigation Unit.

(ii) If the ETIO believes there is not sufficient evidence to warrant the relevant individual(s) being subject to a Disciplinary Procedure, the ETIO will inform the relevant Covered Person(s) that the investigation has finished, that there is not sufficient evidence to warrant the relevant individuals being subject to a Disciplinary Procedure and that the matter is now closed.

(iii) If the ETIO believes there is sufficient evidence to warrant the relevant individual(s) being subject to a Disciplinary Procedure, the ETIO shall inform the relevant Covered Person(s) that as a result of the investigation they will now face the relevant Disciplinary Procedure.

(iv) Following any investigation, the ETIO will submit a report along with the investigatory findings and recommendations to the Chief Executive of the PGAET and the Chief Executive of the IGF or his nominated representative.

5. Disciplinary Procedures, Sanctions and Appeal Process

a) Following the investigation process and gathering of evidence, if the ETIO believes that there is sufficient evidence to warrant the relevant Covered Person(s) being subject to a Disciplinary Procedure, the ETIO shall determine whether the alleged breach of the Regulations should be considered to be a Minor Breach or a Serious Breach of the Regulations, based on the relevant facts, the evidence and findings reported from the investigation and the recommendations made by the Investigation Unit.

An example of a Minor Breach would be:

A Covered Person placing an insignificant and positive bet on a Player’s or Member’s result in a professional or elite amateur golf event.

However in general terms, very few breaches of the Regulations will be considered to be a Minor Breach due to the potential for such breaches to lead to corruption in the game. Accordingly it is likely that the majority of breaches of the Regulations will be considered to be a Serious Breach.

Where the same Minor Breach or a similar Minor Breach is repeated by a Covered Person or where the ETIO considers that a Covered Person may be persistently committing Minor Breaches, the ETIO may determine that an alleged breach, which might otherwise be considered to be a Minor Breach, shall be considered to be an alleged Serious Breach by the relevant Covered Person and in such circumstances the Covered Person shall be subject to the provisions of this Disciplinary Procedure relating to a Serious Breach of the Regulations.

In the event that any evidence (such as testimony from officials, players or other persons) is discovered by, or brought to the attention of, the ETIO subsequent to the initial investigation and/or the decision as to whether an alleged breach is to be considered as a Minor Breach or a Serious Breach for the purposes of this Disciplinary Procedure, then the ETIO shall be entitled to re-categorise the breach as he considers appropriate taking into account such evidence and, if appropriate, the Minor Breach procedure or Serious Breach procedure (as is then applicable) shall be applied.

b) Minor Breach procedure

(i) Decision of the ETIO

Having considered the evidence and findings reported from the investigation and the recommendations made by the Investigation Unit the ETIO shall determine whether on the balance of probabilities a Minor Breach of the Regulations has occurred. If the ETIO determines that a Minor Breach of the Regulations has occurred then he may impose the following sanctions depending whether the Covered Person is a Player, a Member, a Related Personnel or an Employee of PGAET:

(I) If the relevant Covered Person is a Player, a Member or Related Personnel – a warning as to the Player’s, Member’s or Related Personnel’s future conduct or a fine of not less than three hundred and twenty-five Euros (€325) or the Sterling equivalent being two hundred and fifty pounds (£295) and not greater than thirteen thousand Euros (€13,000) or the Sterling equivalent being ten thousand pounds (£11,800).

(II) If the relevant Covered Person is an Employee of PGAET – the evidence and findings reported from the investigation and the recommendations made by the Investigation Unit shall be forwarded to the CEO of the PGAET and HR Director by the ETIO and the Employee of the PGAET shall be subject to the European Tour Disciplinary, Dismissal and Grievance Procedures and shall be subject to such sanctions as the PGAET shall determine in accordance with such procedure.

Subsequent Minor Breaches of the Regulations by a Member, Player or Related Personnel will result in a fine being imposed on that Member, Player or Related Personnel which is twice the amount of the fine for the previous Minor Breach of the Regulations, unless the ETIO decides otherwise. Where a fine of twice the amount of the previous fine is imposed on the Member, Player or Related Personnel, due to the Member, Player or Related Personnel committing a subsequent Minor Breach of the Regulations, the maximum level of fine set out in paragraph b(i)(I) above shall not apply.

(ii) Appeals against decisions of the ETIO

If a Covered Person is dissatisfied with the decision of, or the sanction imposed by, the ETIO, he may appeal to the Tournament Committee by giving written notice to the PGAET within seven (7) days after receiving notice of the sanction. The procedure for any such appeal will be governed by the provisions of paragraph (b)(iii) below.

(iii) Procedure at Tournament Committee Hearing

An appeal hearing before the Tournament Committee is an informal inquiry. There are no fixed rules of procedure and professional representation of the Covered Person concerned is not permitted. The purpose of the hearing before the Tournament Committee is to dispose of the matter as speedily and as informally as possible consistent with a fair hearing and the rules of natural justice. A decision of the Tournament Committee shall be final and binding on the Covered Person.

The hearing will take place before no fewer than three (3) members of the Tournament Committee and any number upwards of that depending on how many Tournament Committee members actually attend the relevant Tournament Committee meeting at which the hearing takes place.

The Covered Person has the right to appear in person before the Tournament Committee and put forward his own explanation of the events surrounding the alleged breach of the Regulations. The Covered Person will be entitled to present his own case in an appropriate manner. The members of the Tournament Committee may question the Covered Person as to his explanation of the events surrounding the alleged breach of the Regulations. Alternatively, the Covered Person shall be entitled to provide written submissions setting out the Covered Person’s version of the relevant incident and any mitigating circumstances which the Covered Person would like the Tournament Committee to take into consideration.

Witnesses will not normally be called but if the Covered Person feels that he cannot do justice to his case unless a particular witness or witnesses are present at the hearing before the Tournament Committee, he shall give written notice to the ETIO to that effect not later than fourteen (14) days prior to the date of the hearing. If the ETIO agrees to such request the Covered Person shall be responsible for procuring the attendance of such witness or witnesses to give evidence before the Tournament Committee in the presence of the Covered Person at the hearing. At the hearing the Covered Person will be given the opportunity to question any of the witnesses present. The witnesses shall also be subject to questioning by the members of the Tournament Committee.

The Tournament Committee shall decide the outcome of the appeal hearing by majority decision and on the balance of probabilities.

The Tournament Committee may give its decision at the conclusion of the hearing or at such time following the hearing as it may consider appropriate. In either case the decision will be confirmed in writing as soon as reasonably practicable.

The role of the Director of Tour Operations (or such other person as may be nominated by the Chief Executive of the PGAET) at a Tournament Committee hearing shall be an administrative role, advising the Tournament Committee on procedure and other matters but the Director of Tour Operations shall not take part in the decision making of the Tournament Committee.

The Tournament Committee shall at any time be entitled to request that the Disciplinary Panel (as constituted in accordance with paragraph c(i) below) consider the appeal if the Tournament Committee decides that the case is too serious or otherwise should not fall within its jurisdiction.

Subject to the provisions set forth in this policy document, any costs incurred by the Covered Person in relation to preparing for and attending a hearing before the Tournament Committee, as well as any costs arising in connection with the attendance of any witnesses requested by the Covered Person at such a Tournament Committee hearing, shall be borne by the Covered Person unless otherwise agreed in writing in advance by the PGAET.

c) Serious Breach

(i) If at the conclusion of the investigation by the Independent Unit into an alleged breach of the Regulations by a Covered Person the ETIO decides on the balance of probabilities that a Serious Breach of the Regulations may have occurred then a disciplinary hearing shall take place before an independent disciplinary panel which shall be formed in accordance with paragraph c(iii) below “Composition of the Disciplinary Panel”.

(ii) Provisional Suspension – The ETIO may make an application to the Board of the PGAET that a Member or Player be suspended from participation in PGAET Sanctioned Tournaments or the accreditation of a Related Personnel or Employee of the PGAET be suspended and their ability to participate or be involved in PGAET Sanctioned Tournaments be denied pending the outcome of an investigation by an Investigation Unit and a disciplinary hearing by the Disciplinary Panel. The Board of the PGAET by simple majority will determine whether such application by the ETIO is granted.

(iii) Composition of the Disciplinary Panel - The Disciplinary Panel shall be an independent and impartial three (3) person panel made up of the following:

i. an independent, legally qualified person (of at least 6 years post-qualification experience);

ii. an ex-member of the PGAET or current player on the Senior Tour; and

iii. an experienced sports administrator (who may have experience in betting related matters).

For each disciplinary hearing, the PGAET shall select the following two persons to sit on the Disciplinary Panel:

  1. An independent, legally qualified person (of at least 6 years post-qualification experience) from a pool of lawyers with the requisite experience (such pool to be appointed annually by the PGAET and which shall consist of up to two (2) eligible persons); and
  2. An experienced sports administrator from a pool of sports administrators with the requisite experience (such pool to be appointed annually by the PGAET and which shall consist of up to five (5) eligible persons).

The Covered Person who is subject to the disciplinary hearing shall be entitled to select the third member of the Disciplinary Panel from a pool of ex-members of the PGAET or current players on the Senior Tour (such pool to be appointed annually by the PGAET and which shall consist of up to five (5) eligible persons).

The legally qualified person selected by the PGAET shall be the chairman of the Disciplinary Panel. Where the Chairman of the Disciplinary Panel considers it necessary, the Disciplinary Panel shall be entitled to appoint external experts or lawyers to advise the Disciplinary Panel, subject to the prior written approval of the PGAET as to the cost of obtaining such external advice.

No person who was involved in the events relating to, or the investigation of, the alleged breach or who has a clear vested interest in the outcome of the disciplinary hearing, or who has made strong statements either way on a directly relevant matter, should sit on the Disciplinary Panel. Each person who is approached to sit on the Disciplinary Panel shall be required to make a declaration of any vested interest or involvement in the alleged breach or the investigation of the alleged breach prior to sitting on the Disciplinary Panel.

(iv) Commencement of Proceedings - The ETIO shall prepare documentation and evidence that the PGAET will rely upon to support the charge that the Covered Person has breached the Regulations and shall send the following (“the Notice”) to the relevant Covered Person and the Disciplinary Panel no later than twenty one (21) days prior to the disciplinary hearing:

i. Notification of the Covered Person’s entitlement to have the matter determined by the Disciplinary Panel at a disciplinary hearing together with the date, time and location of the disciplinary hearing;

ii. Details of the alleged breach of the Regulations by the Covered Person and the Regulation(s) which it is alleged have been breached; and

iii. Copies of the documentation and evidence that the PGAET will rely upon to support the charge that the Covered Person has breached the Regulations (including, but not limited to, written statements).

A Covered Person shall direct any response to a Notice to the Disciplinary Panel with a copy to the ETIO and may respond in one of the following ways:

(i) admit the alleged breach of the Regulations and accede to the imposition of sanctions, in which case no hearing shall be conducted and the Disciplinary Panel shall promptly issue a decision confirming the commission of the breach of the Regulations alleged in the Notice and ordering the imposition of sanctions, which shall be determined by the Disciplinary Panel after requesting and giving due consideration to a written submission from the ETIO on the recommended sanction.

(ii) deny the alleged breach of the Regulations and to have the Disciplinary Panel determine the charge, and if the charge is upheld, the sanctions, at a hearing conducted in accordance with paragraph (c)(v) below.

(iii) admit that he or she has committed the alleged breach of the Regulations specified in the Notice, but to dispute and/or seek to mitigate the potential sanctions. Either a request for a hearing or a written submission solely on the issue of the sanction must be submitted simultaneously with the Covered Person’s response to the Notice. If a hearing is requested, it shall be conducted in accordance with paragraph c(v) below.

If the Covered Person fails to file any response to a Notice then the disciplinary hearing will be held before the Disciplinary Panel as referred to in the Notice.

(v) Procedure at a hearing before the Disciplinary Panel – The Covered Person may be represented and/or assisted at the disciplinary hearing by his lawyer or other such person as he may choose.

At the disciplinary hearing, details of the alleged breach of the Regulations will be presented to the Covered Person and the Disciplinary Panel by the ETIO or a lawyer appointed by the PGAET who shall then present the evidence which supports the allegations that the Covered Person has breached the Regulations. The Covered Person or his representative shall then present the evidence which supports the Covered Person’s version of events and any mitigating circumstances which the Covered Person would like the Disciplinary Panel to take into consideration. All relevant evidence shall be admissible.

The Covered Person shall be entitled to request in writing that a reasonable number of witnesses attend the hearing provided that he serves notice to the Disciplinary Panel to that effect not later than fourteen (14) days prior to the date of the disciplinary hearing. The Covered Person shall be responsible for procuring the attendance of such witnesses to give evidence before the Disciplinary Panel, in the presence of the Covered Person, at the disciplinary hearing. At the disciplinary hearing the Covered Person will be given the opportunity to question any of the witnesses. The witnesses may also be subject to questioning by the members of the Disciplinary Panel. The burden of proof shall be on the PGAET to establish that on the balance of probabilities the Covered Person committed a breach of the Regulations.

The Disciplinary Panel may after hearing all the evidence either give its decision at the conclusion of the hearing or at such time following the hearing as it considers appropriate. In either case its decision shall be conveyed to the PGAET and the Covered Person in writing as soon as reasonably practicable following the conclusion of the hearing.

In reaching its decision, there is no requirement that the Disciplinary Panel will be unanimous. The Disciplinary Panel may decide the outcome of the hearing by majority decision and on the balance of probabilities.

All other procedural rules relating to the disciplinary hearing (including the disclosure of documents and exchange of witness statements) and any modification to the procedural rules in this Disciplinary Procedure (which shall be permissible in exceptional circumstances) shall be laid down by the Disciplinary Panel and notified to the PGAET and the Covered Person (and his appointed representative, if any) as soon as is reasonably practicable prior to the disciplinary hearing.

d) Sanctions and Conditions of Reinstatement

(i) If following a disciplinary hearing, the Disciplinary Panel decides that a breach of the Regulations has been established it shall impose such sanction as it may consider appropriate having regard to the circumstances.

Such sanctions for a Member or Player may range from a requirement that he complete a course of education related to responsible betting, reprimand, censure, a fine, suspension of Membership, suspension from participation in one or more PGAET Sanctioned Tournaments or for a given period of time, expulsion from the PGAET, suspension from any other involvement in the sport of golf, or otherwise as the Disciplinary Panel shall determine.

Such sanctions for Related Personnel may include a reprimand, censure, a fine, suspension or removal of the Related Personnel’s accreditation which permits the holder to access restricted areas at PGAET Sanctioned Tournaments, denial of access to attend PGAET Sanctioned Tournaments, or otherwise as the Disciplinary Panel shall determine.

In the case of Employees of PGAET the findings of the Disciplinary Panel shall be forwarded to the CEO and HR Director of the PGAET by the ETIO and the Employee of the PGAET shall be subject to the European Tour Disciplinary, Dismissal and Grievance Procedures and such sanctions as the PGAET shall determine in accordance with such procedure.

(ii) If following the completion of a Disciplinary Procedure a Member has had his Membership suspended then in order for that Member to be reinstated as a Member or participate in any PGAET Sanctioned Tournament he must have:

i. completed the full period of suspension imposed on him by the Disciplinary Panel or the Appeal Panel;

ii. paid all fines imposed on him by the Disciplinary Panel or the Appeal Panel; and

iii. retaken and successfully completed the Education Course.

e) Appeals against decisions of the Disciplinary Panel

(i) The PGAET or the Covered Person may appeal the decision or sanction imposed by a Disciplinary Panel pursuant to this policy document to a reconstituted Disciplinary Panel (the “Appeal Panel”) by giving written notice of its or his intention to do so within twenty eight (28) days of written notice of the decision having been sent to the PGAET and the Covered Person at their last registered addresses. No person who sat on the Disciplinary Panel in relation to the initial disciplinary hearing shall also sit on the Appeal Panel.

(ii) The notice of appeal submitted by the PGAET or the Covered Person must state the grounds of appeal which shall be based on one of the following:

i. On a matter of fact including the introduction of new evidence;

ii. On a question of the application or interpretation of the Regulations; or

iii. Against the severity or the leniency of the punishment, requesting a reduction or increase in the fine or other sanction imposed by the Disciplinary Panel; or

iv. Any combination of the above grounds.

The appeal will be by way of re-hearing (which shall take place in accordance with the procedure set out in paragraphs c(i) and c(ii) above and otherwise as set out in this paragraph (e)) and the Appeal Panel will consider all and any evidence or information put before it whether or not the same was put before the Disciplinary Panel.

The Appeal Panel shall have the power to admit new evidence including evidence of any third party which the Appeal Panel considers is likely to be affected by the outcome of the Appeal.

In the event of any such written notice of appeal being lodged by the PGAET or the Covered Person, implementation of the decision of the Disciplinary Panel and enforcement of any sanction imposed shall be stayed until the appeal has been heard.

Neither the PGAET or the Covered Person nor their advisors may approach directly or indirectly any of the persons who have already made statements or given evidence before the Disciplinary Panel in relation to the initial hearing (other than those witnesses put forward by the PGAET or the Covered Person respectively), but the PGAET or the Covered Person may request (upon written notice to the Appeal Panel to be delivered no later than fourteen (14) days prior to the appeal hearing) that the Appeal Panel shall use its reasonable endeavours to bring before it such persons for the appeal hearing. If the Appeal Panel is able to procure the attendance of such persons at the appeal hearing, the PGAET or the Covered Person (or their representatives if applicable) will be given the opportunity to question such persons at the appeal hearing. The Appeal Panel may in its absolute discretion adjourn the hearing of the appeal to enable the appearance of any such persons before it. In exercising its functions under the Regulations, the Appeal Panel shall have the power to regulate its own procedure.

The Appeal Panel may after hearing all the evidence either give its decision at the conclusion of the hearing or subsequently as it shall consider appropriate. In either case its decision shall be conveyed to the PGAET and the Covered Person in writing as soon as reasonably practicable following the conclusion of the hearing.

In arriving at its decision the Appeal Panel may either uphold the decision of the Disciplinary Panel or disallow the appeal or it may allow the appeal in whole or in part. The Appeal Panel in its absolute discretion may remit, reduce, increase or otherwise vary any sanction imposed by the Disciplinary Panel.

In reaching its decision, there is no requirement that the Appeal Panel be unanimous. The Appeal Panel may decide the outcome of the hearing by majority decision and on the balance of probabilities. A decision of the Appeal Panel shall be final and binding on the PGAET and on the Covered Person. Subject to the provisions of paragraph (f) below, any costs incurred by the Covered Person in relation to preparing for and attending a hearing before a Disciplinary Panel or an Appeal Panel, as well as any costs arising in connection with the attendance of any witnesses requested by the Covered Person at any such hearing, shall be borne by the Covered Person unless otherwise agreed in writing in advance by the PGAET.

f) Costs

Notwithstanding the foregoing the Disciplinary Panel and/or the Appeal Panel may in its absolute discretion award costs to a successful Covered Person out of the PGAET’s funds or award costs to the PGAET on an unsuccessful Covered Person in such amount and on such terms as to payment as it considers appropriate.

g) Enforcement of Payment

Any fines and/or costs imposed on a Member, a Player or a Related Person by the Tournament Committee, the Disciplinary Panel or the Appeal Panel shall be payable within the time stipulated (except that in the case of an appeal against a decision of the Disciplinary Panel, the payment of any such fines and/or costs shall be suspended pending the hearing of that appeal) and in default of such payment on its due date the Member or Player shall be liable to immediate suspension or expulsion from the PGAET and/or suspended from participating in one or more PGAET Sanctioned Tournaments for a given period of time and the Related Person shall be liable to have his or her accreditation which permits the holder to access restricted areas at PGAET Sanctioned Tournaments suspended or removed.

h) Variation

The PGAET may amend the Disciplinary Procedure from time to time in its absolute discretion and any such amendments shall come into force on the date determined by the PGAET and notified to the Members and other Covered Persons in writing.

i) Waiver of Minor Procedural Irregularities

In the event that there is a breach of procedure by the PGAET, the ETIO, the Tournament Committee, the Disciplinary Panel or the Appeal Panel during the course of any disciplinary proceedings carried out pursuant to the Disciplinary Procedure, this shall not invalidate the proceedings (or any part of them) unless any such breach is so serious that the Covered Person’s position is unfairly prejudiced by such procedural breach to the extent that it would not be possible for the Covered Person to be given a fair hearing.

j) Arbitration Act 1996

The Disciplinary Procedure shall be governed by the Arbitration Act 1996 and amounts to a binding arbitration agreement for the purposes of Section 6 of that Act. The seat of the arbitration shall be England.

k) Governing Law

The Disciplinary Procedure shall be governed by and construed in accordance with English law.

6. *Additional Matters*

a) If any Regulation, rule or provision of this Policy is held invalid, unenforceable or illegal for any reason, by any court of competent jurisdiction, it shall be severed and the remaining provisions of the Policy shall continue in full force and effect.

b) Except as otherwise stated in this Policy, failure to exercise or enforce any right conferred by this Policy shall not be deemed to be a waiver of any such right nor operate so as to bar the exercise or enforcement thereof or of any other right on any other occasion.

7. Definitions and Interpretation

In this Policy the following words and expressions shall have the following meanings, unless the context otherwise requires:

bet – means a wager of money or any other form of financial speculation, including any pay to play gaming and any free to play version of any pay to play game or any other free to play gaming operated by a pay to play gaming entity, (which for the avoidance of doubt shall include any pay to play or free to play Official Daily Fantasy Game of the European Tour (or equivalent) that may exist from time to time).

betting – means making, accepting, or laying a Bet and shall include activities commonly referred to as sports betting such a fixed and running odds, totalisator/toto games, live betting, betting exchange, spread betting and other games offered by sports betting operators.

Covered Person – means any Member, Player, Related Personnel and/or Employee of the PGAET (as the context so requires).

Disciplinary Procedure – means the disciplinary procedure set out in Section 5.

Education Course – means the education and training programmes relating to Integrity in Golf as directed by PGAET from time to time.

Employees of the PGAET – means any individual who is employed by or contracted to provide personal services to the PGAET.

ETIO – means the European Tour Integrity Officer, who will be the person primarily responsible for integrity related issues at the PGAET and will also be responsible for communicating with the IGF in relation to integrity related issues.

ETIP – means the European Tour Integrity Programme. The ETIP will include three elements: the ETIP Blueprint Document, the ETIP Policy Document and the ETIP Education Programme.

IBIS – means the International Betting Intelligence System.

IGF – means the International Golf Federation, being the international federation recognised by the IOC as the world governing body for golf.

IGF Governed Event – means any international golf event which is sanctioned by the IGF including any golf events played at the Olympic Games.

IGF Policy – means the IGF’s policy on betting and anti-corruption as set out in its document “IGF Policies –Betting & Anti-Corruption Policy”.

Integrity in Golf – means the quality of preserving an honest test of skill and ability by promoting professional values and behaviour both on and off the golf course.

Investigation Unit – means an independent unit to be appointed by the ETIO in conjunction with the IGF to investigate potential breaches of the Regulations.

IOC – means the International Olympic Committee.

Members – means the members of the PGAET from time to time.

Other Player - means any other golfer who participates in any professional or elite amateur golf event anywhere in the world.

PGAET or European Tour – means the PGA European Tour, being the international federation that oversees the administration of the European Tour, the European Challenge Tour and the European Senior Tour.

PGAET Sanctioned Tournament – includes any tournament (including any co-sanctioned tournament) that features on the schedules of the European Tour, the European Senior Tour or the European Challenge Tour.

Players – means any individual golfer participating in a PGAET Sanctioned Tournament.

Policy – means this European Tour Integrity Programme Policy Document.

Regulations – means the regulations set out in Section 3 of the Policy.

Related Personnel – means any individual who is associated with a Player including a Player’s manager, agent, caddie, coach, physio, spouse, partner, back room staff, personal sponsor or any other person (including a family member) who receives accreditation at a PGAET Sanctioned Tournament or any other professional golf event at the request of the Member or Player or any other Related Personnel.”

Interpretation

a) Headings used in this Policy are for convenience only and shall not be deemed part of the substance of this Policy or to affect in any way the language of the provisions to which they refer.

b) Words in the singular include the plural and vice versa.

c) Reference to “including” and similar words are not words of limitation.

d) Words importing a gender include any other gender.

e) A reference to a Section is a reference to a Section or sub-Section of this Policy.