TO THE IOC ETHICS COMMISSION

COMPLAINT

Submitted pursuant to paragraph 4 of Section B of the Rules of the Commission by

Indict
P.O. Box 23184
London, England SE1 7WJ

On its own and on behalf of Raed Ahmad, an Olympic Athlete, among others (the "Complainants")

AGAINST

The Iraqi National Olympic Committee and its President, Uday Saddam Hussein

The undersigned Complainant alleges that the Iraqi National Olympic Committee (the "INOC") and its President, Uday Saddam Hussein, have committed and continue to commit gross violations of the IOC Code of Ethics (the "Code") and the Fundamental Principles set forth in the Olympic Charter. In particular, the Complainants allege that the INOC and Uday Saddam Hussein have violated the provisions of the following sections of the Code:

Section A, paragraphs 1, 2, 3, 4 and 5
Section B, paragraphs 1, 5 and 6
Section C, paragraph 1
Section E, paragraph 2

The Complainants allege that the INOC and Uday Saddam Hussein have carried out beatings, torture and harassment of athletes and other persons, in violation of Section A, paragraphs 1, 3, 4 and 5 of the Code. The Complainants allege that the INOC maintains its own prison, in violation of the said provisions of the Code and the Fundamental Principles of the Olympic Charter. The Complainants further allege that the INOC and Uday Saddam Hussein consistently discriminate against athletes and other persons on the basis of race, sex, ethnic origin, religion, and political opinion, in violation of Section A, paragraph 2 of the Code. The Complainants believe that the activities carried out in this regard by the INOC and Uday Saddam Hussein are violations of international standards of human rights, that they constitute crimes against humanity, and that they bring the Olympic Movement into the gravest disrepute.

In addition, the Complainants allege that the INOC and Uday Saddam Hussein are involved in massive corruption, in violation of Section B, paragraphs 1, 5 and 6 and Section C, paragraph 1 of the Code. In particular, the Complainants allege that the INOC maintains warehouses and controls front companies which are used to facilitate smuggling and other illegal activities, profits from which are used for purposes unconnected with the Olympic Movement.

The Complainants further allege that the INOC and Uday Saddam Hussein have violated Section E, paragraph 2 of the Code, by organizing flights and other activities intended to violate the sanctions imposed on Iraq by the United Nations.

The Complainants believe that the above-mentioned violations of the Code and the Fundamental Principles of the Olympic Charter are so extreme and outrageous that they threaten the integrity of the Olympic Movement as a whole. The Complainants respectfully suggest that these violations of the Code and the Fundamental Principles warrant the most severe penalties, including the suspension of the INOC or the provisional or permanent withdrawal of recognition, in accordance with Article 25, Section 2.1.4 of the Olympic Charter.

Complainants

The named individual Complainant, Raed Ahmad is an Olympic athlete. He has made this Complaint at great personal risk. As the evidence submitted with this Complaint shows, the Complainant and his family, as well as the witnesses who have provided statements, have been threatened with death and grievous bodily harm by agents of the INOC and the Iraqi regime. The IOC Ethics Commission is requested to take all measures to safeguard their identity and protect them from reprisal by agents of the INOC and the Iraqi regime.

Indict intends to obtain statements from additional Complainants and other witnesses and will provide these to the Commission in the near future.

Torture, Beating and Harassment

The attached statements of (…), who is an Olympic athlete (Attachment 1), Latif Yahia Latif al-Salihy (Attachment 2) and Abbas Mohammed al-Jenabi (Attachment 3) describe beatings, torture and harassment carried out against them, their families and other persons by Uday Saddam Hussein and others acting under his direction. The videotape entitled "Dispatches: Truth and Lies in Baghdad" broadcast by Channel 4 in the United Kingdom on 17 November 2002 (Attachment 4), contains two interviews with individuals named Hassan Juma and Amar Khalaf, both of whom were tortured by persons acting under the direction of Uday Saddam Hussein.

Indict is aware of many other athletes who have been beaten, tortured and harassed by Uday Saddam Hussein or others acting under his direction, but these athletes are unwilling to make formal complaints due to their fear of reprisal from Uday Saddam Hussein. In addition, Indict has numerous statements from individuals who are not athletes who have been personally tortured by Uday Saddam Hussein. Reports of such torture carried out against athletes and others have appeared in the world media many times over the last six years. The fact that torture has been inflicted upon the orders of Uday Saddam Hussein is confirmed in the attached Report of the United Nations Special Rapporteur dated 24 September 1998 (Attachment 5) and has been reported by Amnesty International in a report dated 14 October 1999 (Attachment 6). Indict intends to provide the Commission with additional videotapes and other evidence of torture committed by Uday Saddam Hussein.

The Olympic Prison

The existence of a special "Olympic Prison" is attested to in the attached statements of Raed Ahmad (Attachment 7), (…), Latif Yahia Latif al-Salihy and Abbas Mohammed al-Jenabi. It is confirmed in the attached Report of the United Nations Special Rapporteur dated 15 October 1996 (Attachment 8).

Discrimination

The attached statements of Raed Ahmad, Latif Yahia Latif al-Salihy, (…) and Abbas Mohammed al-Jenabi describe incidents where athletes have been discriminated against on the basis of race, sex, ethnic origin, religion and political opinion.

Corruption

The attached statements of Latif Yahia Latif al-Salihy and (…) describe financial corruption engaged in by Uday Saddam Hussein and other officials of the INOC. The attached document in Arabic, written in Uday Saddam Hussein's own handwriting, shows that the INOC participated in the looting of Kuwait during the occupation of that country by Iraq in 1990-1991(Attachment 9). The attached article from the Wall Street Journal and translation of an article from al-Hayat newspaper contains interviews with Abbas Mohammed al-Jenabi describing, among other things, the corrupt use of the INOC (Attachment 10).

Violation of United Nations Sanctions

The attached press reports, including a report from the Iraqi Press Agency, demonstrate that the INOC was used to violate the sanctions imposed against Iraq by the United Nations Security Council (Attachment 11). Compliance with these sanctions was and is an obligation under international law and violation of the sanctions is a violation of the Olympic Charter.

Conclusion

The violations described in this Complaint are undoubtedly the most serious breaches of the Code and the Fundamental Principles ever to be brought before the IOC Ethics Commission. They constitute violations of the United Nations Convention Against Torture and the laws of every civilized country. It is inconceivable that a national Olympic Committee which maintains its own prison and torture chambers could remain a member in good standing of the Olympic Movement. Any of the other violations should be sufficient on its own to cast the gravest possible doubts on the fitness of the INOC to participate in the Olympic Movement. The violations committed personally by Uday Saddam Hussein are utterly inconsistent with his position as President of the INOC. These violations warrant the most severe penalties available to the Commission. On behalf of the Complainants, and on our own behalf, we respectfully request that the Commission suspend the INOC, in accordance with Article 25, Section 2.1.4 of the Olympic Charter, and impose such other penalties against the INOC and Uday Saddam Hussein as are appropriate given the seriousness of the violations.

Charles A. Forrest
Chief Executive Officer
Indict
London, England
5 December 2002