This is an archive copy of a document originally located at http://www.ausport.gov.au/events/osf/daly2.htm


RETHINKING THE ETHICS OF SPORT BUSINESS PRACTICES
Jim Daly Adjunct Scholar, University of South Australia
A Full PDF of this presentation (100k) is also available

INTRODUCTION

This paper is written because of a concern that sport is losing its direction and soul to the gods of money and commercial power. So today, I want to focus on the ethical side of sport business practices. There are two handouts available that might be useful in developing and ethical framework for ethical sports business practices.

Don’t switch off because this concerns not only sports administrators and managers, but also the referees, coaches and athletes who are caught up in sponsorship and financial deals and the need to place these in an ethical framework. 

Modern sport is an industry that produces and sells major products and services, it is part entertainment, part commercial advertising, with each element based on the profit motive. Sport in the second millennium is recognised as a business and it therefore faces the challenges of conducting ethical transactions in a very competitive environment.

ETHICAL DILEMMA 

To commence this presentation, let us consider an ethical dilemma, to test your sports ethics and provide an insight into how difficult it is to make an ethical decision about who should provide the funds for the construction of the new grandstand at the Adelaide oval. 

There are no clear-cut rights or wrongs, but I ask you to put yourself in the position of having to make a decision on how you would use public money in these circumstances? You don’t have to reveal your answer. 

An announcement was made by The Hon. Kevin Foley, Treasurer of South Australian Government in July last year; `that the government would not be honouring a commitment by the previous government to provide $11m towards the cost of a new grandstand at the Adelaide Oval’. He said. `If they (the South Australian Cricket Association - SACA) want a grandstand, they can build it themselves’.

Rex Jory, a journalist for the Advertiser wrote on 10th July 2002 that; `Only the silvertails will fret at the oval cut’1. This comment led to an angry letter to the paper on 17th July from the Ian McLachlan, President of SACA who said that; `The reason for SACA Board approaching the government was that Adelaide needs to compete in the business of providing facilities for sport at the highest level, because that’s what it is, a competitive business between cities and venues’. 

On the 7th August a letter to the Advertiser by Patrick Neville of Aldinga who criticised the Rann government for withdrawing the $11m. He said that the grandstand was necessary to; `Ensure that South Australia remains competitive, especially in international cricket enhancing the State’s public profile, attracting more tourists and giving the economy a boost’. Another letter the next day from Dr Tony Shinkfield, a respected educator was even more direct when he wrote; `This is dismaying …. perhaps worse is the abysmal short sightedness of the Labor Government – is political parsimony at its worst’. 

Another letter appeared at the same time from Henry Underwood (Modbury) who said; `Sanity has come about with respect to public expenditure – it has been apparent for some time that the government really had to get back to basics and concentrate on such things as health and education; before luxuries’. 

Construction has since commenced on the grandstand and all of the additional funds were raised from financial resources within SACA. 

Hypothetical Questions 

ETHICS AND VALUES

These are terms that are often avoided because they are considered personal and associated with emotional rather than objective thinking. The recent emphasis on corporate governance in the business sector has driven home the need for business ethics to be taken seriously because ethics do affect the bottom line. From a sports point of view, ethics are a growing concern when related to drug abuse, on-field incidents and off-field behaviours; but ethics are in their infancy when it comes to how sport handles the business practices of amateur and professional clubs, associations and the growing number of privately owned and managed sports organisations.

What are Ethics

The word ethics comes from the Greek word, `Ethos’, which means the essence of one’s character. We use the term to refer to the ultimate values and principles one holds. Ethics are defined in a recent Australian Sports Commission `Ethics in Sport - research with individuals and organisations in Australian sport’ report as; `about respect, integrity, justice, democracy, fairness, equity, doing the right thing and duty of care for participants, officials, administrators, coaches and the public (eg spectators)’.3 

What are Values 

Values overlap with ethics being closely connected to personal integrity and personal identity, they are the foundations on which we make decisions and they usually reflect the society in which we are part. They can change and as the cultural identities of nations change because of global impacts. 

As Suzanne Ross put it; `ethics is about asking one simple question when faced with personal and sporting decisions at all levels: `What ought one to do?’4 Answering this question of what ought one to do means we are operating in the ethical dimension. Making it a matter of practical concern.

The Sunlight Test

A good guide to sport business ethics is the sunlight test. Your business behaviour should be able to stand scrutiny by anyone. All actions and decisions should be capable of being transparent to the public gaze. For example, how would you feel if everyone who you respect and admired knew what business deals you had just made, because they were on the front page of daily paper or on the six o’clock TV news that night? 

The Golden Rule

The one rule that is paramount in both personal and business ethics is the `golden rule’, which seems to be a common thread throughout the world: Always treat others (business clients and colleagues), as you would like them to treat you. This is the basis for reciprocal treatment and sets the pattern for ethical sports business relationships. 

MYTHS AND REALITIES OF MODERN SPORT

Myths are an integral part of sport; in fact most of the legends become myths in the telling and retelling of the great moments and these great moments add colour to our lives. Today we will focus on the myths and realities associated with sport business practices. Let me assure you that these are as colourful as the other myths and legends associated with playing sport. But as a hard-nosed economist I need to ground the myths in realities. 

Myth 1 Sport is just `Fun’ and `Games’ – a diversion from everyday life. 
It is easy to adopt this line when money is tight and the politicians are looking for a way out of funding sports and recreation programs and facilities. 

Reality
We have to realise that sport brings out the worst as well as the best in us. And there is a need to place sport in a wider social and ethical context. Sport is culturally and socially important to the Australian way of life and it makes a significant contribution to the economic sector. Recreation goods and services rose from $60.2 billion in 1996-97 to $78.1 billion and export earnings from sport and recreation goods and services rose from $355.7 million in 1997-98 to $497.7 million in 2000-2001.5 

Sport is the biggest voluntary organisation in Australia and therefore it serves as an important binding agent for Australian society. But sport faces many threats to its image and in my opinion is heading for a values crisis about how funds are distributed and where these funds come from. There are also conflicts of interest among sports policy makers and administrators with increasing competition between high profile sports that attract big sponsorships. In addition there is a cynicism about the commitment to grass roots community sport that have been considered the building blocks for sport development. 

Myth 2. Grow or Die
It essential that sports clubs and associations grow or they will die. Too many clubs and associations live in the past and therefore they will die. It is only the input of new ideas that appeal to successive generations that will stimulate growth. 

Reality
There are serious problems to our single-minded pursuit of growth. It leads to “slash and burn “strategies. Cost cutting and downsizing are popular tactics to achieve apparent growth in profits that usually leaves an organisation and their members without direction, energy and hope. Less focus should be directed to growth in profits and size. Maybe there is something to be said for being satisfied to retain what is important, because our real enemy is greed for power linked to the false god of continued growth. The environmental movement has much to teach us about finite resources and the effects of growth for the sake of growth. 

As James Carlopio in the Financial Review said; `the existing business paradigm based on short-term growth and prosperity for the few – is both morally bankrupt and self-destructive.6 

Myth 3. Sport is Like Any Other Marketable Commodity
Modern sport has entered the postmodern era as a just another range of goods and services to be traded freely at the best price in an open market. It is just another tool of modern capitalism, particularly when athletes and teams are traded as commodities. 

Reality
Sport reflects part of the Australian national identity, which is based on a democratic model with a Westminster system of government. Imbedded in sport are such values as free speech, democratic decision-making, the right to organise and equal opportunities. The extent to which these values are practiced should be always under review. 

In fact high priced business motivational speakers often use examples from the sporting world to demonstrate how to develop high performances, teamwork, and leadership skills. A new book coming on to the market next month by my psychologist friend Graham Winter is entitled, `Performance Leadership: The Business Athlete Strategy’. This says it all.

Certainly there is an increasing emphasis on treating sport as a business; but understanding the nature of sport goes much deeper because it integrates Australian values also reflected in the cultural, sociological, historical, biological, psychological and artistic areas of life. Sport is an expression of our Australian identity, it is not like any other commodity; being different things for different people. 

Myth 4. Globalisation of Sport is Inevitable
Top class sports are becoming ever more commercial as local, national and international borders are more obscured. Sport today is all about numbers and TV ratings to get money to operate successfully. 

Reality
Whether we like it or not, globalisation is a reality. It is foolish to deny the reality of global forces. As Keith Sutter, a social and ethical commentator points out; `The challenge is to find ways of coping with globalisation – the clock cannot be turned back to the more stable and secure world of the 1950s.7

On the ABC radio program; “The Sports Factor” earlier this year, Hans Westerbeek, said; `Globalisation is not something evil in its own right, it can turn evil when applying wrong principles or the wrong value systems or narrow-minded values systems to it and that is where the whole system falls down if you indeed only apply Americanised or westernised values to sport in a global context’.8 

Fortunately there are a number of other forces operating in sport that deny the inevitability of globalisation. One of these is the convergent theory, which as the name implies suggests that globalisation will homogenise sport. But this is wrong because; `no nation is able to escape its background or entirely free itself from national bias’.9 

I disagree with the conclusion in the Sport Industry Australia draft report on the Status of Sport in Rural and Regional Australia that says; `Australia belongs to the process of modernisation, streamlining and privatisation’ 10. 

A good example, of how globalisation can be broken down at the international level is when full time professional athletes such the Australian soccer team members particularly Harry Kewell resisted pressures from his English soccer club Leeds United to stop him participating the `friendly’ against England recently. This highly paid player opted for his Australian loyalties that overcame the global soccer pressures placed on him by his Leeds club. Money was not important because although their match payments were nowhere near what they usually receive; they were all positive that this match was a highlight in their careers. 

Globalisation is not a forgone conclusion, there are national loyalties that extol cultural identities, but clear directions need to be established that make it easier for athletes to reach what are essentially hard ethical business decisions.

A visual example of the tendency to produce homogeneous sports products is the increased competition among cities for sports facilities in which to organise mega-sporting events such as the Olympics. Look at the design of two stadia on different sides of the world. You will recognise the photo on the left as the stadium built for the Sydney Olympics (now called Telstra Stadium) and the one on the right is being designed at Wembley, which may form part of a bid for a London Olympics. Note particularly the similarity of the curved grandstands. Gone are the unique local design characteristics that give a ground historical character and we are left with a kind of homogenised global architecture. 

Telstra Stadium Sydney            Wembley Stadium London

Telstra Stadium Sydney (left) and Wembley Stadium London (right)
Note! The similarity in design features, particularly the arches 

Myth 5. The Media are the New Owners of Sport
There is a strong link between sport and the media particularly in Australia and this follows a global trend. Our media moguls have a strong influence on the development of Australian and ultimately world sport. Examples include Kerry Packer who repackaged cricket to suit television audiences in the 1970s and Rupert Murdock who took over the development of Rugby League and formed the Super League in recent years. Did you know that the Australian Rugby League (ARL) is 50% owned by the National Rugby League (NRL) and 50% owned by News Limited? Rugby needs the media to survive, but without the media exposure and sponsorship the ARL would not have developed to the present level.

The photo below is an example of how sponsorship dollars are being used by the media (in this case electronic media Telstra) associated with swimming and Ian Thorpe. 

The photo below is an example of how sponsorship dollars are being used by the media (in this case electronic media Telstra) associated with swimming and Ian Thorpe.
Ian Thorpe shows off his sponsor’s logo. 
He has currently 11 major corporate relationships (sponsors)

Reality
On the other hand, the media needs sport to fill in their programs and obtain high ratings. Modern media and information technology are to a large extent responsible for the reality of mass sport. Nevertheless global TV and its accompanying commercial activities tend to produce a popular sport culture and this can be used to create national pride and loyalty because no nation is able to escape its background, which even further diversifies the local differences. National and regional sports are fast learning to use local media for broadening the marketing of sport. 

We have a very saleable product and changes to media ownership will bring new players at regional levels into particularly television broadcasting and this will assist to dissipate the present national and international monopolies of the media moguls and in time sport will become stronger and more able continue to control its own destiny. 

As Neil Plumridge, Vice-president of Global Management Consultancy says; `Sport is no longer a chummy locker room where deals are made on a handshake.11 Increasingly sports organisations are now employing staff with business management qualifications as their chief executives and managers. 

Ethical questions need to be asked about how some sports use the profits made from television, sponsorships and from merchandising sports products. It is not clear how these financial windfalls advantage sports development at national, regional and community levels. Also, how could the distribution of profits on a more equitable basis occur to support national and regional sports organisations? 

Myth 6. Sport should be left in the hands of the Private Sector
The argument goes that sport should be free of all interference from government and be allowed to develop like any other business with private sector support. 

Reality
The bottom line in businesses is to make a profit, but over the last 10 years business corruption has forced former hard-nosed business executives and their boards to consider the environment and community in which they operate. You have heard of terms such as “double bottom line” and triple bottom line”; these force boards of companies to take into consideration environmental and community considerations as well as the traditional profit bottom line. If business is changing and sport has an increasingly business focus, then it is obvious that we should also widen our focus to consider the community/social role of sport. 

Shareholders in companies are now cynical about the ethical standards of businesses since the collapse of Ansett, OneTel, and HIH because of corporate greed and lack of disclosure. Self-regulation did not work, so there is now much more emphasis is being placed on business ethics and `corporate governance’. This has forced changes by introducing government regulations to raise business standards. I hope sport can learn from the business sector and take seriously the inevitable changes occurring in sport governance and a business practices. The extent to which an ethical framework for sport business practices can be established will depend on the way sport can learn from the traumatic changes in corporate governance that are now taking place. The Ethics in Sport Survey suggests that along with other problems, `inappropriate administrative practices’ have the greatest impact across all levels of sport.12 

On top of the need to improve sport governance is an increasing surveillance by government at all levels, mainly because they are more than concerned than ever that the taxpayer’s money is being allocated equitably and to meet government agendas. I suspect one reason why we are here at this Forum is because sport is increasingly being called upon to account for its results, both qualitatively and quantitatively. 

Sport is more than a marketable commodity and therefore it cannot be left in the hands of the unregulated free enterprise private sector. Although business opportunities will continue to grow at particularly global and national levels, ethical checks and balances need to be considered and this is what we will attempt in the next section of the paper. 

ETHICAL SPORTS BUSINESS PRACTICES 

Sports ethics are well established in coaching protocols, sports medicine, and performance enhancement by drugs, but sports ethical business practices are not yet on the agenda.

Two Key Issues
There are many issues that need to be addressed but two specific ones related to sport business are:

As with Chief Executives in the business sector who are paid enormous incomes, there are a small number of high profile athlete’s earning amounts far beyond the imagination of most of us. For example, Lleyton Hewitt (who is a nice young Adelaide boy 22 years of age) earns an estimated $25 million through tournament prize money, sponsorships and endorsements for just swinging a racket.13 The ethical issue is one of fairness and equality of distribution; it is hard to justify this type of income when other athletes are struggling to just stay in the sport. 

Shareholders of companies are now querying these exorbitant payouts, but sports organisations do not have shareholders as such, so who can query or put pressure on sponsors and the media to redistribute some of the payouts to elite athletes? 

As Barry Houlihan points out;` the weak diminishing role of governing bodies is substantially the result of the intensity of commercialisation and the long-standing fragmentation and mutual suspicion between governing and organising bodies’.14 Another example of a sport where administration has not come to grips with the need to change business practices is Soccer Australia. This has resulted in the Australian Sports Commission launching an Independent Soccer Inquiry, which has as its primary role to examine the governance, management and structure of soccer in Australia. Renmo Nogarotto, the recently elected head of Soccer Australia acknowledges that; `the answer is in setting a financial criteria which will probably, at the end of the day, end up with a mix of new and existing franchises’.15 Unless they get it right, this time, then accordingly to Warwick Hadfield, the presenter of the ABC program; The Sports Factor, ` The Australian Securities and Investment Commission will probably declare them insolvent’.16 

In his book on amateurism in sport, Allison argues that: `throughout the 1990s the control of `our’ games and sports has ebbed steadily away in the direction of global sports associations and global media corporations’.17 If this is so, then the power base of sport changes from community based decision making to undemocratic decision-making at national and global levels. If there is no transparency at the top, who looks after the values and ethics of sport?

As we have seen, corporate governance is the big issue in both the business sector and now also in the sports sector. The exposure of such questionable sport business practices as corrupt unelected and unrepresentative members of the International, Olympic Committee under the presidency of Juan Antonio Samaranch are increasingly coming under public scrutiny. 

Closer to home, we have examples of questionable boardroom ethics when the AFL Chairman Ron Evans made the following public comment of the Carlton Football Club board in November last year ; `a deliberate, sophisticated and elaborate scheme implemented by some former directors of the Carlton Football Club to breach the total players payments provisions of the AFL’s Rules’.18 This cost the club a fine of $930,000 plus an additional fine of $50,000 recently incurred for another salary cap breach and Carlton were also stripped of their draft choices.

We also find the ARL team, Canterbury Bulldogs have breached the salary cap and this saw them demoted to the tail of the field late in the regular 2002 season. At the time the misdemeanour was revealed, the bulldogs were in first place and certain minor premiers. 

The Canberra Canons have had corporate difficulties and almost went into liquidation. Some of their games were suspended and the Australian Securities and Investment Commission investigated them. 

The exposure of these and other corporate governance incidents has made other sports administrators aware of the damage done to world and national sports organisations by corrupt unelected and unrepresentative members of incompetent administrations. Perhaps the lessons learned by sport at the global and national levels will flow down to sports organisations and clubs. 

ETHICAL FRAMEWORK FOR SPORTS BUSINESS PRACTICES

As a first step towards developing an ethical framework for sports business practices, I suggest the following 10 commandments adapted from some work by Anita Roddick, Founder of The Body Shop.19 

Ten Commandments for Ethical Sports Business Practices

  1. Establish ways in which local players and sports organisations are able to negotiate fair deals from global corporations.

  2. Eliminate market-distorting confidential deals with hidden incentives.

  3. Strengthen local, national and international ownership and protection of intellectual property, personnel (players and athletes) and products. 

  4. Establish partnerships with like-minded businesses of good character with knowledge of local sports cultures in the countries in which the business operates.

  5. Adhere to the highest international sports standards regarding human rights, player conditions, health and safety in both the facilities built and managed and work environments.

  6. Establish a code of ethics that provides guidelines and standards for the operation of the sports business.

  7. Ensure that safeguards are in place to stop money laundering, trading in illegal drugs, corporate tax evasion, anti-competitive practices such as price-fixing cartels.

  8. Obey the law in the country in which the sports business operates.

  9. Do not join or participate in global sports conglomerates that concentrate global corporate power in the hands of unrepresentative organisations.

  10. Provide safeguards to constantly review the business purpose of sports clubs and associations to prevent ethical standards slipping. 

SUGGESTED WAY FORWARD

We can learn at least one salutary lesson from the ethical failures of former respected companies. This lesson is that if some leading companies are unethical, this affects the public confidence of the whole sector. Similarly, poor business ethics in one sport will affect everyone in the sports industry. Whether we like it or not, dodgy sport business practices will increasingly come under the scrutiny of statuary regulators such as the Australian Securities and Investment Commission. 

The proposed model for introducing ethics into sport business practices is in part one that was proposed for South Australian sport, but it was not taken up, although preliminary work was done on it before I retired in 2000.

Step 1
Top management must be committed to implementing ethical business practices. There must be a consistent and ongoing organisational will to drive reforms right through the organisation. It is interesting that the findings of the Ethics in Sport research undertaken by the Sports Commission indicated that 72% of National administrators are most likely to rate ethics as extremely important today and 76% rate ethics as important in the future;20 so the signs are good. 

Step 2
Appoint a senior staff person responsible for ethical sport practices and make sure that this subject is a regular agenda item at all top management meetings.

Step 3
Establish an `Ethics Committee’ with clout by electing a cross section of members from players, coaches, management and other staff. This committee must be seen to be democratic and have the power to open usually closed sports management processes to democratic processes. Above all the committee should encourage transparency in decision making at all levels of the sports organisation. Principle-centred leadership must evolve from this committee.21 I commend to you a book by Stephen Covey on this subject. 

Step 4
Codes of Ethics are now a feature of most business organisations and also many sports organisations, but these are only platitudes that usually end up displayed on the wall, but they are rarely put into practice in a systematic way. 

I suggest that the Ethics Committee develop an enforceable code of ethics (or code of conduct) for the sports organisation as one of its first tasks. Developing a code of ethics will focus the committee and it was a priority recognised by 70% of sports administrators and 89% of Officials/referees in the recent ASC Sports Ethics Research Paper. 22 

Step 5
Conduct an environmental scan of the sports organisation. It is suggested that a person from outside the organisation with skills as an ethicist be hired for this purpose. Each person in the organisation should be asked to rate his or her association on how ethical issues are addressed using a scale of 1-10.

Step 6
Develop a strategy by: 

Step 7
Establish a review and evaluation procedure that involves a regular internal audit of ethical issues. Unfortunately, self-regulation does not always work, so “gatekeepers” are needed to set an ethical framework for sports business practices. As Simon Longstaff, noted Australian ethicist says; `We need groups of people who act as gatekeepers not just guns for hire’.23 

These gatekeepers must have the following credentials:

It is interesting to note that 89% of national administrators and 78% of local and state administrators agree that the ASC should monitor ethical issues in sport. There is support for a continuing and extended ASC role in the ethical areas. 24 

Effective Leadership and Management

Good business practices depend on ethical leadership and management. A prerequisite for good sports governance is an awareness of the changing societal cultures and values and attracting people to fulfil positions of leadership in sports organisations. Leaders should not only have high ethical standards in their personal lives, but also transfer these values/standards into their sporting and administrative roles. After this perquisite is in place, other leadership and management skills are required such as: 

CONCLUSION

An ethical society is based on all citizens being able to reach their full potential and control their lives. The same applies to sports participants; they should be able to reach their full sporting potential and control their control their sporting lives. 

It is inevitable that business practices will increasingly be important to the future of sport at all levels. The message is; will sport have to learn the hard, bitter ethical lessons of the corporate sector with the accompanying loss in community support that followed their excesses of the 1980s and 90s. Can we be smart enough to avoid the corruption, greed and double-dealing of the business sector by putting into place an ethical framework that constantly requires maintenance and evaluating in the light of a changing society in which sport operates?

It is not good enough to leave the future of sport to chance and an ethical approach to sports business practices is very important in the overall scheme of things. The following concurrent session will commence the task of developing an ethical framework for sport. 

Finally, my little bird called Australia (Sport) below has two choices. Either she clings to the past and refuses to fly so crashing to the bottom of the cliff, or she flies up to greater heights and on to the future. The future of Australian sport is up to you. 

REFERENCES

Adelaide Advertiser, 10th July 2002

Sage. George H. Power and Ideology in American Sport (1998) Human Kinetics. USA. p.292 (110)

Australian Sports Commission (2003) Ethics in Sport – Research with individuals and organisations in Australian Sport. ACT Reference 3589 7200. p.7 

Ross, Suzanne; What is the Value of Ethics? Ethics Newsletter of the St James Centre, Sydney

Australian Bureau of Statistics (2001-2002) Australian System of National Accounts 5204-02 Table 50 

James Carlopio BOSS Annual (2002) in The Financial Review p.41

Suter, Keith In Defence of Globalisation, (2000) NSW Press, Sydney, p.10 

Westerbeek Hans (2002) Radio National The Sports Factor 6th December 

King Yan Ho (2000) Convergent process and diversified growth of national sport experience in this global village in Old borders new borders no borders Meyer & Meyer Sport. P.78

Sport Industry Australia (2001) The Status of Sport in Rural and Regional Australia, Draft Report ps7,10

Plumridge, Neil. To win, sport must kick global goals, in the Australian Financial Review, 28th June 2002

Australian Sports Commission Ethics in Sport – Research with individuals and organisations in Australian Sport

Herald Sun, Melbourne; 19th September 2002

Houlihan, Barry [1997] Sport, Policy and Politics – A comparative analysis, Routledge, London

Remo Nogarotto (2003) Radio National The Sports Factor 10th February

Warwick Hatfield (2003) Radio National The Sports Factor 10th February

Allison, Lincoln (2001) Amateurism in Sport – An Analysis and a Defence, Frank Cass, London, p.47 

Evans Ron (2002) Statement by AFL Commission Chairman, 2nd November

Anita, Roddick Take It Personally - How Globalisation affects you and powerful ways to challenge it. (2001) Thorsons London. p.230

Australian Sports Commission Ethics in Sport – Research with individuals and organisations in Australian Sport

Covey, Stephen. R (1992) Principle Centred Leadership. Simon and Schuster. USA 

Australian Sports Commission Ethics in Sport – Research with individuals and organisations in Australian Sport. p.13

Longstaff, Simon [2002] The Decline of Ethical Behaviour. In the Australian Financial Review, Friday 19th April 2002

Australian Sports Commission Ethics in Sport – Research with individuals and organisations in Australian Sport

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This is an archive copy of a document originally located at http://www.ausport.gov.au/events/osf/daly2.htm
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