The case involves a legal dispute between FC Rubin Kazan, a Russian football club, and Denis Gennadievich Tkachuk, a professional football player, along with the Russian Football Union (RFU), regarding unpaid bonuses stipulated in the player's employment contract. The dispute was adjudicated by the Court of Arbitration for Sport (CAS), with the award issued on 28 August 2019. The central issue revolved around whether the club was legally obligated to pay bonuses to the player under the terms of the contract and related bonus regulations, despite the club's claims of financial difficulties and unsatisfactory team performance. The employment contract, signed on 16 May 2016, included an annex detailing bonus payments, which were later formalized in the "FC Rubin Kazan Provision Season 2016/2017 Individual Bonus Scheme" (Bonus Regulations). These regulations outlined specific bonus amounts for victories and draws in the Russian Premier League and Russian Cup, with payments partially deferred until the end of the season based on the club's final standings. The player argued that the bonuses were contractually binding, while the club contended they were discretionary and subject to the Director General's approval.
The arbitrator examined the case under the Labor Code of the Russian Federation (LCRF), which stipulates that wages and bonuses must be specified in employment contracts or collective agreements. The arbitrator concluded that the Bonus Regulations, as an annex to the employment contract, were binding and made bonus payments mandatory. The arbitrator emphasized that the purpose of a bonus scheme is to motivate players by providing clear and certain rewards for achieving specified results. The club's financial constraints and claims of poor performance were deemed insufficient to absolve it of its contractual obligations. The arbitrator also noted that the club's delayed communication about withholding bonuses was misleading and could have negatively impacted team morale, especially since the team achieved satisfactory results, including reaching the semi-finals of the Russian Championship.
The case highlighted the legal principle that once bonus provisions are established in an employment contract, they become binding, and any changes require the employee's consent. The club's unilateral decision to withhold bonuses without prior notice or justification was found to violate contractual and labor law obligations. The CAS ultimately ruled in favor of the player, dismissing the club's appeal and upholding the decision of the RFU Dispute Resolution Chamber. The ruling reinforced the importance of honoring contractual agreements and the binding nature of bonus schemes in employment contracts, regardless of a party's financial situation. The club was ordered to pay the unpaid bonuses, and all other requests for relief were dismissed. The case underscores the complexities surrounding player bonuses in professional football and the legal obligations of clubs to adhere to agreed-upon terms.