LCFC are well placed to implement the Fan Led Review (FLR) White Paper as a minimum but are looking to go further as appropriate.
1.What does the FLR White Paper cover?
The government will appoint an independent regulator to oversee the reform of football. All 116 clubs in the top five tiers of the English football pyramid will require a licence from the Regulator to operate as professional men’s football clubs. The licences shall require clubs to meet the following four Threshold Conditions:
- Appropriate resources
The club must have adequate financial and non-financial resources and controls in place, to meet committed spending and foreseeable risks. - Fit and proper custodians
Persons at a club deemed to exercise significant decision-making influence must be fit and proper custodians. - Fan interests
The club must have appropriate provisions for considering the interests of fans on key decisions, and issues of club heritage, on an ongoing basis. - Approved competitions
The club must agree to only compete in leagues and competitions that are approved by the Regulator based on predetermined criteria.
2.Why have the club have embraced the Fan-Led Review?
We are of the view that English football has proved incapable of self-governance in the face of several challenges and a changing landscape. Reform is much needed if we are to ensure a sustainable and resilient football pyramid for the benefit of fans and the local communities football clubs serve.
As the current guardians of LCFC we are acutely aware of the bigger picture as described in the White Paper given the clubs historic difficulties and near extinction as well as our current challenges in delivering a sustainable model.
Unlike typical businesses, football clubs are community assets with cultural heritage value. In addition to the direct and indirect economic benefits they deliver to local areas, they benefit wider society. Clubs often engage in community initiatives and contribute to civic identity and pride in place.”
To address specifically our approach to the fan interest’s threshold condition we start from a strong position. Fan engagement is a long-term focus of the club and concerted efforts have led to good progress being made with our recent achievement of the EFL Gold award for Family Excellence as an example. This commitment to run the club with a strong consideration for fan interests is why LCFC see the Fan-Led Review as an opportunity and sought to engage with our fans proactively back in September 2022 through an FLR Working Group.
3.Who are LCFC’s FLR Working Group and what is their remit?
While wanting to keep the group small and focused, it was seen as critical the broadest possible representation could be achieved with the hope that this would improve reach and diversity in connecting with fans.
The below graphic illustrates the composition of the group and the roles they play in terms of representation of our fan base.
Each point of contact is responsible for:
- ensuring the fan group know they are represented on the FLR working group, maintaining reasonable ongoing communication with the group, sharing information, and inviting feedback on subjects as appropriate to the FLR.
- bringing the voice of the fan group into the FLR working group
- identifying any need to reprofile the group to better represent its community.
- redirecting non FLR enquiries to the appropriate area within the club, shadow board or Trust
Since September ’22 the group has met eight times and worked through:
- reviewing and discussing Tracey Crouch’s FLR Report to begin preparations for how the key fan bodies will organise and operate going forward
- ensuring true representation of our fan base
- reaching out to fans for input
- reviewing the government White Paper and preparing a response
- making a proposal to the Board on the way forward
The main outcomes can be summarised as follows:
- Informed by key documents and discussions the Trust and Supporters Board have both undertaken reviews of their constitution, representation, governance, processes, and skills using a RAG approach resulting in action plans. This has been good preparation for their roles in the post FLR world.
- There has also been progress in identifying opportunities for closer co-operation between fan groups with the Trust and Supporters Board welcoming members of each onto their Boards. Additionally, the Trust has reached out to the FSA for available guidance and tools and the Supporters Board have consulted with other clubs.
- Outreach with fan groups has resulted in revitalised connections, new connections and aided the formation of new groups such as the Disabled Supporters Association. Representation for the Women’s team as part of the Supporters Board has been initiated in line with the White Paper recommendation. There are still many opportunities to strengthen further the network through the implementation phase.
The government white paper was published on 23 February, 2023, it represents a political decision to protect the social status of football. It made the following provisions for considering fan interests on key decisions, and issues of club heritage as a minimum requirement.
- Clubs shall be required "to have appropriate and proportionate provisions for considering the interests of fans on key decisions and issues of club heritage". In this respect, the Regulator shall work closely with the FA, which is itself updating its rules to protect club heritage assets, such as the club badge, name, and home colours.
- Rather than introducing the proposal to give fans a “Golden Share”, it is proposed that the Regulator will require clubs to collect proof that a majority of fans are in favour of a change, “giving fans an effective veto over changes to these intrinsic representations of their club’s history and heritage.”
- Stadium sales and relocations shall also require pre-approval of the Regulator, who shall consider “the historical connection to a specific location, views of supporters and the local community, and the impact on other clubs in a new location before giving approval”.
After discussing the White Paper in detail and considering its provisions in the context of the original Fan-Led Review the main conclusion of the FLR Working Group was that LCFC’s strong performance in fan engagement can be further enhanced by going “above and beyond” the minimum requirements of the White Paper.
The FLR working group subsequently prepared a proposal for consideration at the April Board meeting based on the following key thoughts:
- The Fan-Led Review report is widely praised for its recommendations to bring about meaningful and lasting reform. The golden share and shadow board elements represent a step change in considering the interests of fans.
- This is an opportunity to bring our fan groups closer together through common objectives, formalised ways of working and the responsibility of delivering a single voice on key decisions and issues of club heritage.
- Improved fan representation is fundamental to increased fan involvement in a say in the direction of the club.
- The focus on connecting with our fans in recent years and the strong performance on the fan engagement index and in the EFL awards are proof that we continue to live our vision of being "a club to be proud of".
- While there is a high level of trust between the club and its fans it is prudent to consider how we can future proof fans involvement and interests in its club.
On this basis the FLR Working Group set out its proposals for the club going “above and beyond” In terms of the shadow board and Golden share.
The FLR working group also requested that the board consider appointing a Fan Engagement Director from its existing membership to support the implementation of the White paper and as a commitment to furthering the good work in this area.
At the board meeting of 27 April, the FLR Working Group's proposal was discussed and there was broad agreement that we should look to encourage and enable meaningful change in fan interests whilst ensuring we don’t create any unintended consequences that may hold back development of the club or create complexity and conflict. In agreeing any changes there would have to be clarity in definition, feasibility and the mechanisms for enactment.
Agreement in principle was given to the following:
Shadow Board
It was noted that the Regulator would aim to enable flexibility for clubs by formulating and implementing Specific Licence Conditions and offering guidelines on how they can comply with them during the assessment process.
LCFC implementation:
- Indicating change through renaming the Supporters Board to Fan Advisory Board.
- Evolving governance and processes in key areas such as constitution, remit, representation and approaches to member election, communication, and administration in order to deliver:
- evidence (e.g. a memorandum of understanding, meeting agendas, minutes) that a club has an established efficient structure in place for senior personnel to engage in frequent discussions of important strategic issues with a representative group of supporters.
- a representative group must include, at the very least, a club's supporters' trust and sufficient representation for the affiliated women's team, if one exists and considerable percentage of this representative group of supporters should be chosen, elected, or invited to attend these meetings, in compliance with fundamental democratic principles and in agreement with the broader fanbase's.
Golden Share
It was noted that:
- the government has no intention of prohibiting any club from adopting a "Golden Share" model (i.e. a special share held by a club’s Community Benefit Society requiring fan consent for certain actions). Nevertheless, the government believes that the Regulator could ensure appropriate safeguards are implemented for club heritage throughout the football pyramid via alternative measures.
- Regarding the club badge, name, and home shirt colours, the government considers that the FA’s Club Heritage Regulations are less complex and provide fans with the same degree of protection as a "Golden Share". These protections are already in place, and once implemented, the regulator will guarantee their regulatory basis.
- The Regulator will introduce additional protections for club stadiums by obliging all clubs to seek prior approval for any sale or relocation, whereby the Regulator would evaluate the implications of any proposal.
LCFC Implementation:
1. A newly created Golden share held by the Trust as a CBS and only being triggered if the Trust/Fan Advisory Board considers it necessary in the following scenarios:
- any proposed change to the name of the Stacey West Stand.
- proposals for the sale of the current ground and relocation to a new stadium elsewhere if proposal is outside city of Lincoln (definition to be agreed).
- significant heritage matters including a change or amendments of club name, colours, badge, Imp logo (exact details to be defined)
2. In addition, the Fan Advisory Board to be informed and consulted on:
- any major sponsorship deal for the club (for the stadium, stands, shirts, etc) that fans might consider to be unethical or inappropriate in any other way:
- a significant change of club ownership or control.
Nominated Board level official for fan engagement.
Following a proposal by the FLR working group, the board considered and agreed the appointment of a director responsible for fan engagement. The role objectives and responsibilities were agreed as follows:
The appointment of a director responsible for Fan Engagement is designed to further advance and demonstrate our clubs’ commitment to ensuring long term meaningful engagement with fans.
A nominated Board-level official, the FED will oversee the club’s fan engagement activities, working closely with the CEO and head of supporter services (Rob Noble).
The key responsibilities of the FED are:
- Steering the Fan-Led Review working group from recommendation through to implementation.
- Liaising with the Red Imps Community Trust to align strategy and plans as holders of the golden share.
- Membership of the Fan Advisory Board (FAB) with a focus on effectiveness.
- Encouraging a culture of fan engagement throughout the club
- Ensuring true representation of our fanbase in engagement
- Annual Fan Engagement Plan (FEP) presented to board*
- Preparation, presentation, and communication of an annual board Fan Engagement Report, outlining the engagement activities undertaken and key issues / concerns raised from fans in that season.
- Summary statement on fan engagement for annual report
- Support a communication approach that is transparent, informative, accurate and timely.
- to learn and to develop our approach to fan engagement.
*The FEP should include, but not be limited to:
- Fan survey results & insights
- Performance KPI’s
- FE Statement for Annual Report
- Details of key fan engagement activities to be completed during the season.
- Details of key roles and responsibilities of club officials in relation to fan engagement
- Details of the Fan Advisory Board such as membership, frequency
- of meetings and reporting
- Details of all club Heritage Assets requiring fan consultation prior to a material amendment
The board agreed by election David Lowes as the first holder of the post with the intention of rotating the position among board members going forward.
At the Board meeting on 24 August, a review of our FLR and fan Engagement approach was reviewed.
Key topics were:
- The FLR working party process and recommendations.
- Fan Representation
- A fit for purpose Fan Advisory Board
- A fit for purpose Trust
- The Golden Share
- The role of the Head of Supporter Services
- The role of the director responsible for fan engagement
- A draft first fan engagement strategy and plan