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Abstract

The 2022 World Cup has been largely criticised. Indeed, detractors of the events notably pushed much criticism concerning the attribution of the event to Qatar. Nevertheless, the majority of the critics revolved around the conditions that migrant workers had to face in the country. Those workers were employed for the construction of infrastructures necessary for the organisation of the event. Hence, this article dives into the negative aspects of the competition, more precisely concerning precise processes which took place during the setup of the 2022 World Cup. Furthermore, this article underlines the positive outcomes that emerged from the controversies regarding the treatment of migrant workers. In fact, it is now possible to observe a certain ‘progress’ in terms of their rights. This development allows us to question the place of human rights in the organisation of future international sports events, notably the 2024 Paris Olympic Games, which are already subjected to some controversies. 

Introduction

64 matches, 32 teams, 1 winner, and many controversies. As the 2022 World Cup in Qatar is wrapping up, now is time for an assessment. We are not experts in sport, nor in its result, it is thus not on that aspect that we shall focus. It is important however to consider the numerous controversies pushed forward by the World Cup in Qatar, as well as the potential progress it created. Through this article, we intend to analyse if the 2022 World Cup, and especially, if the political and social issues that were emphasised, were, in the end, beneficial for the progress of human rights at the international level, but also nationally, in Qatar. Firstly, we will come back to the issue of the hosting attribution, given to Qatar, and the accusation of corruption that followed. Further, we will analyse the impact the World Cup had on the situation in Qatar. Next, we will consider its impact on FIFA’s interest in human rights to, finally, conclude with a focus on the 2024 Olympic Games and the potential lesson that the World Cup could give to worldwide sports events. 

The attribution of the World Cup to Qatar

Since the announcement of the hosting of the 2022 World Cup by Qatar, many controversies emerged: the process of attribution, the environmental consequences of the competition, and the outrageous working conditions in Qatar that led to the death of many migrant workers. 

The 2022 World Cup took place in Qatar after a vote from the FIFA Executive Committee (ExCo) during a double attribution conference in 2010. This attribution surprised the general public as Qatar did not start as a favourite to organise the event. Many arguments in the technical report of Qatar demonstrate it, notably its difficult weather and lack of infrastructure. Such conditions for an attribution thus created many suspicions about the legitimacy of the votes and about possible corruption within FIFA and members of the ExCo. Indeed, FIFA and some of its members had in the past been involved in corruption as they offered or accepted diverse bribes and advantages in exchange for certain votes and decisions. In May 2015, 14 members of FIFA were arrested by the FBI within the framework of a federal investigation regarding corruption1. We consider that throughout the years (until 2021), more than 50 people were incriminated in this investigation2.

For now, there is no concrete evidence of corruption regarding the attribution of the World Cup to Qatar. Nevertheless, some testimonies create plausible doubt. This is notably the case of Phaedra Almajid’s testimonies, a former employee of Qatar’s campaign for the hosting of the competition, who condemn the corruption conducted by Hassan Al-Thawadi, the general secretary of the organisation committee of the World Cup. The latter, according to Phaedra Almajid, offered 1.5 million US$ to three members of the FIFA ExCo to ensure that they will vote for Qatar during the 2010 conference. Considering the extent of her revelations, Phaedra Almajid ended up denying her own testimony. She, later on, added that she changed her revelations out of fear for herself and her family3. Furthermore, the close time frame between some geopolitical agreements and the vote engendered further doubts about Qatar’s hosting legitimacy. 

Doubts about a scandal of corruption regarding this World Cup however do not revolve solely around FIFA members. Indeed, on December 9, 2022, five individuals including members of the European Parliament were arrested for suspicion of corruption linked to Qatar. Advantages and gifts are thought to have been offered by Qatar to push the concerned individuals to improve the image of the country regarding human rights and the workers’ condition. Four of the five arrested individuals are now incarcerated for “affiliation to a criminal organisation, money laundering, and corruption.4

Hence, this  context of corruption within FIFA and the European Parliament only amplifies other controversies regarding the World Cup. We will thus analyse the impact of those controversies on the political and social issues that they put forward. 

What has changed in Qatar with the World Cup

The majority of workers involved in the construction of the diverse infrastructures needed for the event are migrant workers. Amnesty International unveiled some statistics: according to May Romanos5, migrant workers represent 95% of the country’s labour force6. The NGO also mentions the increased presence of those workers on Qatari territory because of the pressing needs linked to the organisation of the World Cup: in 2010, 1.1 million migrant workers were present on the territory while now, the number rises up to 2.2 million7

Their mission in Qatar is colossal. In a bit more than a decade, they had to construct all the infrastructures Qatar needed to organise the competition. Thus, between 2010 and 2020, 8 stadiums had to be created, as well as an extension of the airport, a new metro system, new hotels to welcome the public, as well as roads8. This deadline created this necessity for the frantic pace of construction which was detrimental for many workers. 

The Kafala System

Migrant workers’ rights violations are associated with a permissive context. Indeed, to obtain the right to work in Qatar, workers depend on their employer as regulated by the Kalafa system, or patronage system. In some cases, the sponsors resorted to the confiscation of passports to prevent any way out of the territory. It is also necessary to mention that, until 2018, workers could neither switch jobs nor leave the territory without the agreement of their bosses. This created situations in which the employee was threatened by his employer and could not leave the country, even without a salary9

Under the pressure of many actors, such as NGOs and IOs, Qatar had to revise its social law and notably put an end to the Kafala system. In 2016, Qatar announced its abolishment, but only the word ‘patronage’ disappeared from the legal instruments10. In practice, this announcement did not bring out any changes, meaning that workers still had to obtain authorisation from their employers to leave the country or switch jobs. Furthermore, after the declaratory effect of that decision, critics regarding the Qatari regime continued. One had to wait until the beginning of 2020 for Qatar to implement a new law aiming at suppressing an essential component of that system: the authorisation of the employer to switch jobs11

This progress recognised by the international community is important. Nevertheless, in practice, there are still many recent testimonies that allow us to consider that the Kalafa system still exists. For instance, in a report on working conditions in Qatar published on November 16, 2021, Amnesty International demonstrates that some work offers ask for documents proving the authorisation of the former employer to switch jobs12

Fees deposited to agencies 

Workers are often vulnerable to abuse from agencies that put them in contact with Qatari companies. Indeed, in some cases, workers must pay them a fee to “ensure” their job. Those fees are another mechanism to trap workers. As they are in debt, they have no choice but to abide by the demands that are imposed on them. Those debts are not directly contracted to the employer, but to the agency that linked the two parties. Yet, we can still question the responsibility of the Qatari companies regarding their knowledge of those methods. 

In 2014, the government reacted with the “Workers’ Welfare Standards”. This policy specified that the companies have to make sure that the worker did not have to pay any fee to obtain that job. The employer, according to this decision, had the duty to refund the worker if the latter had to pay fees13. Nevertheless, this policy is disappointing in practice. An audit of the Supreme Committee of 2021 demonstrated that 68% of workers in construction had paid fees of around 1.333 US$14

Working conditions and salary payment

Alongside the unbearable working conditions, numerous workers denounced the missing salaries or compensation that does not correspond to the work they have done. The situation caused the workers to strike in October 2022, even despite the risk they expose themselves to. Some sources reveal that some workers would not have perceived any salary for 5 months, which is notably the case of employees of Bin Omran Trading and Contracting15

Against this, Qatar implemented a minimum salary of 1.800 rials (464€) while also putting an end to the Kafala system. Nonetheless, the regime’s lack of resources to control companies is denounced by many. Thus, abuses remain. 

The Guardian published an investigation denouncing the death of 6.751 workers between 2010 and 202016. This represents almost 13 deaths per week. The newspaper attributes those deaths to the difficult working conditions workers have to endure. On the other hand, official sources only recognised a few working accidents and mention much more natural causes of death. Amnesty International denounced this position, affirming that according to scientific studies, working conditions in Qatar – high temperatures and humidity – might be the cause of death of young workers with no previous signs of diseases17. As of now, there is no universal agreement on the number of deaths in the framework of the construction of the infrastructure for the competition18

Despite the refusal from Qatar to recognise the number of deaths on the construction sites, new legislation qualified as “progressive” was implemented to forbid working in the heat19. Qatar is actually one of the first countries in the world to put in place such a law. It is now forbidden to make workers work between 10 am and 3:30 pm during summer. The statistics that were reported in the following years demonstrated the reduction in the number of workers hospitalised because of the heat. Nevertheless, scientific studies indicate that the high humidity levels, even outside of the agreed hours of the reform, make working conditions dangerous. What is called thermic stress continues to cause deaths and health issues among workers in construction fields. It is worth noting that, as for the other reforms that Qatar implements, the lack of resources to control their implementation makes us question their effectiveness. Thus, many construction fields continue to function during the forbidden hours. 

The Qatari right to work regarding migrant workers

What has also contributed to creating a permissive environment and a situation of impunity for employers violating human rights are the few rights allocated to migrant workers in Qatar. Indeed, Qatar joined the international agreements of the International Labour Organization (ILO) and the ONU agreements20 which protect trade union rights. Nevertheless, by joining those agreements, Qatar put reservations in place. Thus, the term ‘trade union’ is limited by its national interpretation made according to Article 116 of the Qatari Labour Code, and merely authorises Qatari citizens to enjoy those rights21. This excludes migrant workers as they cannot form or join a trade union. Furthermore, they are also forbidden to demonstrate or strike. One also needs to consider their dependency on other factors, such as financial pressure, preventing them from practising these rights.

The ILO thus considers that there is still a long way to go to obtain solid guarantees for all workers in Qatar. Ruba Jaradat, the Regional Director of the ILO for Arab States, announced that: “It is a long way to go with Qatar – and the reforms and cooperation with the international community are indeed important for the region. We all recognise that we are not at the finish line, and we will rely on this solid base to fill this void in the implementation and to ensure that all workers and employers are able to benefit fully from those major reforms.”22

The impact of the 2022 World Cup on FIFA’s consideration of human rights

As previously mentioned, the proceedings of the World Cup in Qatar embarrassed FIFA but also allowed it to face its responsibilities. Controversies already shook FIFA during the 2018 World Cup in Russia, but the ones that emerged from the World Cup in Qatar had a greater extent. It is unfortunately impossible to qualify them as historical considering the rate of audiences of this event, especially in France. Hence, Qatar considers this World Cup to be successful. 

Revelations regarding the working conditions of migrant workers caused one to question the consideration of human rights issues by FIFA. The organisation rarely spoke about it, getting itself off the hook by putting the emphasis on the responsibility of the organising countries. 

For once, FIFA could not escape its responsibilities. The seriousness of the situation obliged the organisation, as soon as 2015, to call John Ruggie (1944-2021) – a former UN Special Representative on Human Rights and Transnational Corporations and Other Business Enterprises from 2005 to 2011 – so that he would develop a policy regarding human rights issues23. His report was submitted on April 14 2016 with many recommendations24

This resulted in the modification of FIFA’s status, especially Article 3 which now plans that “FIFA engages to respect all human rights internationally recognised and that it will do everything to promote the protection of those rights.”25

Consequently, FIFA took the decision to adhere to the UN Directive Principles regarding enterprises and human rights issues, called the “Ruggies principles”26. The organisation did not always recognise those, benefitting from its special status despite its economic activities. For all that, the OECD was encouraging FIFA to recognise them since 2015, considering that those activities made it a company27. Alongside this, FIFA also engaged itself to respect the International Charter of Human Rights28

Now, it thus has to limit activities with negative repercussions on fundamental rights, being either social rights, working conditions, non-discrimination, or even the right to property (regarding the expropriation of locals to construct stadiums). 

One of the key measures put in place was to implement an advisory council for human rights with 8 independent experts in March 2017. Its role was to produce periodic reports to encourage FIFA to adapt its policy29. From 2017 on, it alerted FIFA on the conditions of workers for both the World Cup in Russia and Qatar30. Nevertheless, the council had no power to obligate FIFA to respect its recommendations, thus significantly limiting its influence. Regrettably, its mandate had terminated and has not yet been reconducted after its final report in 2021. 

This acknowledgment of fundamental rights by FIFA seems late considering the number of deaths and violations that occurred. The respect of those rights is vowed to be a determining criterion in future World Cup attributions. For all that, it is difficult to trust FIFA considering the numerous pieces of evidence of corruption, pushing us to question the degree of importance that the respect of those rights will have in future applications. Will money take precedence over social issues and respect for human rights? The actual measures are only declaratory. One must wait to see if FIFA will respect them, especially during the attribution of the 2030 World Cup considering the 2026 one is already decided to take place in North America.

Without the respect of those engagements, one can hope for FIFA to be subjected to judicial consequences. We can only regret the lack of judicial proceedings against FIFA despite the complaints of three trade union organisations against the organisation for omitting to act upon the working conditions of migrant workers in Qatar in 201731

Conclusion: Could the World Cup in Qatar be a lesson for the organisation of future sports events? A focus on the 2024 Paris Olympic Games

By questioning the fact that sports events such as the World Cup can now act for human rights, it is necessary that the organisation leading the event make them a priority, especially regarding financial issues. For the World Cup in Qatar, it is obvious that the organisation of such an event, at those workers’ expense, is outrageous. If we try to see the glass half full rather than half empty, it is possible to say that those controversies helped to make the sphere of social rights in Qatar “progress” to a certain extent. This would not have been the case if the World Cup would have happened somewhere else. Indeed, countries surrounding Qatar did not abolish their Kafala system since there was no pressure from public opinion. 

The durability of that progress can also be questioned. Will Qatar continue to fight for the development of social rights respecting migrant workers? For NGOs, the World Cup was an important opportunity brought by the media to exert a hold over the country with strong international pressure. Will the interest in the working conditions of those migrants in Qatar remain at the heart of public opinion? Unfortunately, the answer seems pessimistic as one controversy replaces another. We must hope that organisations such as the ILO continue their work despite the absence of public pressure as the base for change is already established.

This World Cup is also an opportunity for following more attentively what will happen regarding future sports events. The next major event will take place in France for the 2024 Paris Olympic Games. On a legal aspect, the French legislation is more protective of its workers than the Qatari legislation. Nevertheless, there might be a gap between the theory and the facts. Recently, Libération published an article highlighting the mediocre working conditions that undocumented workers employed in construction fields of the Olympic Game face32

As a reminder, the Olympic Games and the World Cup are not dependent on the same international sports organisations. The International Olympic Committee (IOC) which organises the Olympic Games is traditionally more cautious of the respect for human rights. 

In this case, the article in Libération demonstrates the consideration of the workers’ human rights. Undocumented workers explained being employed by subcontractor enterprises for months, or years for some. In short, apart from the working conditions, they denounce low salaries and unpaid overtime. Furthermore, they have neither construction uniforms, security shoes, nor health visits. For now, the problem doesn’t seem to be contained despite the recurring controls from health and safety inspectors. As for the IOC, some surveillance measures were implemented to ensure good working conditions on construction fields according to Bernard Thibault, a member of the committee33.

It seems now that inspecting organs might function, alert and encourage organisers to implement fast measures to contain and stop those situations. For the World Cup or the Olympic Games, it seems like inspections are being increased during major sports events, thus imposing on us two questions. Do the other construction fields need fewer inspections as they represent fewer risks for violations? Or is it because they are less visible to the advocates of human rights and the rest of the population?

Moreover, it questions the fastness of execution imposed on those construction fields. An event of such an extent cannot be delayed, even by a day. Thus, are the applications validated by the IOC and FIFA strong enough? Are those executive organs taking into consideration the time it takes and the actual infrastructures necessary before attributing a host?

Those huge events display the recurring and anchored issues linked with workers’ rights in Qatar and France. Will those events be capable of limiting or even annihilating this kind of negligence in the long term, for instance by adopting legislation or by creating or reinforcing independent inspecting organs? In a more utopian way, would it be possible to condition the organisation of such an event to the annihilation of those issues? 

It will be interesting to see how those issues are handled during the putting in place of the Olympic Games and future editions of the World Cup. This will allow us to consider the extent to which social and political issues emerging from big sports events will objectively be taken into account nationally and internationally.

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To quote the article:

DANDEU, E. FRARY-AUBERT, S. MAZZOLINI, C. & POMMIES, L.(2022). Que retenir de la Coupe du monde 2022 au Qatar ? Generation for Rights Over the World. growthinktank.org. [online] Dec. 2022.

Acknowledgments

We thank Jeanne Delhay and Marie Chapot for their proofreading.

©Renovation of the Khalifa International Stadium, Doha, Qatar (roof & cooling)” by jbdodane is licensed under CC BY-NC 2.0.

References
1 N. D. (2015). Fifa corruption crisis: Key questions answered. bbc.com [online] 21 Dec. Available at: https://www.bbc.com/news/world-europe-32897066 [Accessed 15 Dec. 2022].
2 GORDON, D. (2022). FIFA: Ballon rond et corruption. Netflix, 2022.
3 BOND, D. (2011). Qatar 2022 ‘whistleblower in corruption U-turn. bbc.com [online] 10 Jul. Available at: https://www.bbc.com/sport/football/14098944 [Accessed 15 Dec. 2022].
4 N. D. (2022). Soupçons de corruption en lien avec le Qatar: la vice-présidente du Parlement européen écrouée. Ouest-France.fr [online] 11 Dec. Available at: https://www.ouest-france.fr/europe/ue/soupcons-de-corruption-en-lien-avec-le-qatar-l-eurodeputee-eva-kaili-inculpee-et-ecrouee-237f4534-794e-11ed-af6e-4db4880eec0a [Accessed 15 Dec. 2022].
5 Member of Amnesty International.
6, 7, 17 Amnesty France. (2022). Les exploités du Qatar. Youtube. Available at: https://www.youtube.com/watch?v=wG_TVmJ0zmw [Accessed 15 Dec. 2022].
8 HRW. (2022). Qatar: Rights Abuses Stain FIFA World Cup: ‘Reporters’ Guide’ Highlights Key Labor Rights Issues, Needed Reforms. Human Rights Watch. [online] Available at: https://www.hrw.org/news/2022/11/14/qatar-rights-abuses-stain-fifa-world-cup [Accessed 15 Dec. 2022].
9, 13 HRW. (2022). Human Rights Guide For Reporters: 2022 FIFA World Cup in Qatar. Human Rights Watch. [online] Available at: https://www.hrw.org/sites/default/files/media_2022/11/202211mena_qatar_worldcup_reportersguide_2.pdf [Accessed 15 Dec. 2022].
10 BELKAID, A. (2022). Au Qatar, la « kafala » pèse toujours. Le Monde diplomatique [online] 21 Oct. Available at: https://www.monde-diplomatique.fr/mav/156/BELKAID/58115 [Accessed 15 Dec. 2022].
11 OIT. (2019). Au Qatar, des réformes majeures du droit du travail mettent fin au système de la kafala. Organisation internationale du travail. [online] 16 Oct. Available at: https://www.ilo.org/global/about-the-ilo/newsroom/news/WCMS_724343/lang–fr/index.htm [Accessed 15 Dec. 2022].
12 Amnesty International (2021). Reality Check 2021: A year to the 2022 World Cup – The state of Migrant Worker’s Rights in Qatar. Amnesty International. p14 [online] 16 Nov. Available at : https://www.amnesty.org/fr/documents/mde22/4966/2021/en/ [Accessed 15 Dec. 2022]
14 Impactt. (2022). Annual External Compliance Report of the Supreme Committee for Delivery & Legacy’s Workers’ Welfare Standards: Shifting focus to delivery and legacy. Impactt. [online] Available at: https://www.workerswelfare.qa/sites/default/files/reports_item/field_document/Sixth%20Impactt%20Ltd.%20Compliance%20Report.pdf [Accessed 15 Dec. 2022].
15 HRW. (2022). Qatar: Wage Abuses by Firm in World Cup Leadup: ‘Migrant Workers Unpaid for up to 5 Months; Protection Systems Fail. Human Rights Watch. [online] 3 Mar. Available at: https://www.hrw.org/news/2022/03/03/qatar-wage-abuses-firm-world-cup-leadup [Accessed 15 Dec. 2022].
16 McINTYRE, N. et PATTISSON, P. (2021). Revealed: 6,500 migrant workers have died in Qatar since World Cup awarded. Theguardian.com. [online] 23 Feb. Available at: https://www.theguardian.com/global-development/2021/feb/23/revealed-migrant-worker-deaths-qatar-fifa-world-cup-2022 [Accessed 15 Dec. 2022].
18 DAGORN, G. & DEROEUX, I. (2022). Qatar 2022 : pourquoi il est très difficile d’estimer le nombre de morts liés aux chantiers de la Coupe du monde. Le Monde. [online] 14 Nov. Available at: https://www.lemonde.fr/les-decodeurs/article/2022/11/14/qatar-2022-pourquoi-il-est-tres-difficile-d-estimer-le-nombre-de-morts-lies-aux-chantiers-de-la-coupe-du-monde_6149784_4355770.html [Accessed 15 Dec. 2022].
19 BAKER, A & KASHI, E. (2022). Thousands of Migrant Workers Died in Qatar’s Extreme Heat. The World Cup Forced a Reckoning. (s. d.). Pulitzer Center. [online] 3 Nov. Available at: https://pulitzercenter.org/id/node/28251 [Accessed 15 Dec. 2022].
20 International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights in 2018.
21 UN Treaty Collection. (2022). International Covenant on Economic, Social and Cultural Rights. [online] Available at: https://treaties.un.org/Pages/ViewDetails.aspx?src=IND&mtdsg_no=IV-3&chapter=4#EndDec [Accessed 15 Dec 2022].
22 OIT. (2022). Quatre ans de réformes du travail au Qatar. OIT. [online] 1 Nov. Available at: https://www.ilo.org/global/about-the-ilo/newsroom/news/WCMS_859890/lang–fr/index.htm {Accessed 15 Dec. 2022].
23 FIFA. (2017). FIFA’s Human right policy. Fédération Internationale de Football Association. [online]. May. Available at: https://digitalhub.fifa.com/m/1a876c66a3f0498d/original/kr05dqyhwr1uhqy2lh6r-pdf.pdf [Accessed 15 Dec. 2022].
24 RUGGIE, J. (2016). For the Game For the World. Harvard Kennedy School. [online] Available at: https://www.hks.harvard.edu/sites/default/files/Ruggie_humanrightsFIFA_reportApril2016.pdf [Accessed 15 Dec. 2022].
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26 UN. (2011) Guiding Principles on Business and Human rights. United Nations. [online] Available at: https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf [Accessed 15 Dec. 2022].
27 OCDE. (2016). Rapport annuel 2015 sur les Principes directeurs de l’OCDE à l’intention des entreprises multinationales 2015. OCDE. [online] Available at: http://mneguidelines.oecd.org/2015-Annual-Report-MNE-Guidelines-FR.pdf [Accessed 15 Dec. 2022].
28 The International Charter of Human Rights encompasses the 1948 Universal Declaration of Human Rights, the 1966 International Covenant on Civil and Political Rights, and the 1966 International Covenant on Economic, Social and Cultural Rights.
29 LATTY, F. (2020). La FIFA et les droits de l’Homme au Qatar. Le tournant global en droit international privé, Pedone. HAL Open science. [online] Available at: https://hal.archives-ouvertes.fr/hal-03200440/document [Accessed 15 Dec. 2022].
30 N. D. (2017) Football. Mondial 2018 : le conseil des droits de l’Homme de la Fifa s’inquiète “des graves risques” pour les ouvriers. Ouest France. [online] 9 Sept. Available at: https://www.ouest-france.fr/sport/football/football-mondial-2018-le-conseil-des-droits-de-l-homme-de-la-fifa-s-inquiete-des-graves-risques-pour-5367442 [Accessed 15 Dec. 2022].
31 N.D. (2016). Fifa lawsuit (re migrant workers, Qatar). (s. d.). Business & Human Rights Resource Centre. [online] Available at: https://www.business-humanrights.org/en/latest-news/fifa-lawsuit-re-migrant-workers-qatar/ [Accessed 15 Dec. 2022].
32 GURVAN, K (2022). Sans-papiers sur les chantiers de Paris 2024 : “Les JO ne pourraient pas se faire sans nous”. Libération. [online] 5 Dec. Available at: https://www.liberation.fr/societe/sans-papiers-sur-les-chantiers-les-jeux-olympiques-ne-pourraient-pas-se-faire-sans-nous-20221205_3IOA3NFTMZBADLDM35V7OVI3TI/ [Accessed 15 Dec. 2022].
33 N.D. (2022) JO 2024 : une dizaine de travailleurs sans-papiers sur le chantier du village des athlètes. Le Figaro. [online] 29 Mar. Available at: https://www.lefigaro.fr/sports/jeux-olympiques/jo-2024-une-dizaine-de-travailleurs-sans-papiers-sur-le-chantier-du-village-des-athletes-20220329 [Acessed 15 Dec. 2022].

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