The British Horseracing Authority (BHA) has announced the conclusion of the investigation and completion of the report into the 22 horses stabled at Godolphin’s Moulton Paddocks yard in Newmarket which are known to have been administered with anabolic steroids. These horses were all under the care of the then licensed trainer Mahmood Al Zarooni until his disqualification on April 25, 2013.

Following a review of the findings of the report, the BHA has decided not to issue any further Disciplinary charges. There was no evidence of any other parties being involved with the administration of prohibited substances beyond those identified at the Disciplinary Panel hearing on April 25th. In addition, no evidence was found to challenge or dispute the findings of the Disciplinary Panel with regard to the events which took place within the yard. The findings and reasons of that Disciplinary Panel can be found here.

The investigation did not find any evidence to suggest the decision to use anabolic steroids involved those that can be considered as Al Zarooni’s superiors or any of the other senior figures at the yard, including the Assistant Trainer, Charlie Appleby, and Head Lad, Oliver Costello. However, the investigation did highlight a number of key failings both in terms of process and within the management structure at Moulton Paddocks. This created an environment in which these offences were able to be perpetrated by Al Zarooni without being detected by others within the yard.

The investigation found that Al Zarooni was able to act in a manner which marginalised several of his senior staff, which subsequently resulted in these events being able to unfold entirely without their knowledge or oversight.

The key findings of this report have been submitted to Godolphin management as a guide to implementing immediate structural and procedural changes which the BHA considers are necessary at Moulton Paddocks. The full copy of this report can be found here.

Following two interviews with the BHA and the conclusion of the wider investigation, the BHA is satisfied that there is no evidence that Charlie Appleby was involved in, or aware of, the administration of prohibited substances to horses at Moulton Paddocks. The BHA also noted Charlie Appleby’s recent measures to instigate changes to procedures and processes within the yard, alongside Saeed Bin Suroor, in whose yard none of the failings associated with Moulton Paddocks were found, and for who Charlie Appleby had worked for long periods as a Godolphin employee. Consequently the Licensing Committee has approved Appleby’s application for a licence to train from Moulton Paddocks, with immediate effect.

The BHA has an existing and robust stable yard inspection and equine anti-doping and medication control programme. It was this programme that uncovered these serious breaches of the Rules of Racing. However, the yard will be subject to enhanced monitoring for a period of time until the BHA is satisfied that a reduced level of scrutiny would be appropriate. This will include the BHA making both announced and unannounced visits to Moulton Paddocks to carry out further testing and monitor progress of the implementation of changes within the yard as a result of this report.

Adam Brickell, Director of Integrity, Legal and Risk for the BHA, said: “After an extensive and thorough investigation we have found no new evidence which contradicts that which was presented to the Disciplinary Panel. The evidence gathered from this investigation has confirmed that Mahmood Al Zarooni acted autonomously and was the person solely responsible for the events that took place at Moulton Paddocks.

“However, we have identified significant failings in the processes in place and management structure at the yard which allowed these events to unfold without senior management becoming aware. These findings have been shared with Godolphin.

“We are satisfied that Charlie Appleby had no awareness of the actions of Al Zarooni. This was made clear to the Licensing Committee, which has confirmed that Appleby is suitable to hold a trainer’s licence. We are aware that Appleby has already begun the process of implementing changes to the management structure and procedures at the yard and we will encourage him, as the licensed trainer, to continue to implement such changes, including addressing all of the points set out in our report.”

“Conversely, Al Zarooni’s refusal to cooperate further with the investigation will be drawn to the attention of the Licensing Committee should he ever seek to return to British Racing following his eight-year disqualification.”

Paul Bittar, Chief Executive of the BHA, added: “The investigation process has been a complex and challenging one. However, I am satisfied that the conclusions reached are an accurate reflection of events.

“Fortunately cases such as this – both in terms of scale and profile – are incredibly rare, however there are areas where we can learn from the issues raised. One such area is in respect of the work now being carried out with the IFHA to improve levels of harmonisation between racing jurisdictions on the use of anabolic steroids, where encouraging progress is being made. This case may well prove to be a catalyst for significant policy change in some countries.

“While we believe the sport’s independent regulation has stood up throughout this process, the BHA is committed to continue to fight against those who attempt to cheat the sport. As such, this case has also led to a review into our anti-doping programme to ascertain whether the appropriate level of resource is being deployed and whether it is being deployed in the most effective way. The BHA’s anti-doping budget has, due to the broader economics of the sport, undergone a significant reduction in recent years and this case highlights the need to ensure we remain at the forefront of world racing in terms of our programme and resources.”

The Investigation

The following details the timeline of events from the start of the investigation to its completion.

• Apr 9th: Unannounced testing in training takes place at Moulton Paddocks. Samples are taken from 45 horses.
• Apr 16th: HFL Sport Science, the laboratory responsible for conducting the sample testing inform BHA of four unusual screening findings for stanozolol. Verbal authorisation given to proceed to confirmatory analysis. Later that day, seven further samples were reported as screening positive for ethylestranol. Confirmatory analysis authorised for these further samples.
• Apr 17th: Enquiries are made at Moulton Paddocks. Godolphin are informed of the initial findings and an interview is held with Mahmood al Zarooni. Al Zarooni admits to ordering 15 horses be given steroids (five stanozolol & 10 ethylestrenol). These included all 11 horses which have screened positive, plus four additional, untested horses. A statement is also taken from Sharif Mahboob (Veterinary Assistant).

Ethylestrenol:
Certify
Desert Blossom
Fair Hill
Ghost Flower
Orkney Island
Sweet Rose
Valley Of Queens
Comitas*
Sashiko*
Vacationer*

Stanozolol:
Artigiano
Bathrat Amal
Opinion Poll
Restraint Of Trade
Tearless*
* Admitted by Al Zarooni but not initially tested

• Apr 22nd: Confirmation is received from HFL of all 11 positive samples. Details published by BHA and all 11 horses are suspended with immediate effect.
• Apr 24th: Publication of the charges against Al Zarooni and the suspension of four further horses based on the admissions by Al Zarooni.
• Apr 25th: Al Zarooni Disciplinary enquiry. Eight year penalty imposed with immediate effect. All 15 horses involved are suspended for six months from the date of the initial samples being taken (9th April).
• Apr 29th: Further testing of all horses at Moulton Paddocks begins.
• May 2nd: Samples taken from all horses at Godolphin’s Snailwell Rd yard (all trained by Saeed bin Suroor). All later returned clear.
• May 2nd onwards: During the course of May and June 2013, a significant number of interviews took place as part of this investigation. Amongst others, the following Godolphin employees and contractors were formally interviewed by BHA Investigating Officers and, in some instances, Jamie Stier, Director of Raceday Operations and Regulation:

o Simon Crisford (In capacity both as Racing Manager to Godolphin and authorised representative of Sheikh Mohammed bin Rashid Al Maktoum of Dubai)
o Charlie Appleby (Assistant Trainer – Moulton Paddocks)
o Oliver Costello (Head Lad – Moulton Paddocks)
o Sharif Mahboob (Veterinary Assistant – Moulton Paddocks)
o Arvind Pillay (Foreman – Moulton Paddocks)
o Sashan Jadhav (Foreman – Moulton Paddocks)
o Rob Pilsworth (Veterinary Surgeon based primarily at the Snailwell Road yard of Saeed Bin Suroor but also providing occasional cover at Moulton Paddocks)
o Chris Osborne (Veterinary Surgeon based primarily at the Snailwell Road yard of Saeed Bin Suroor but also providing occasional cover at Moulton Paddocks)

In some cases the above named were formally interviewed more than once throughout the course of the investigation.

In addition, several attempts were made to contact both Mahmood Al Zarooni and Veterinary Surgeon Fred Van Der Linde. However, these attempts were unsuccessful, so BHA has relied on the initial interviews with Al Zarooni and the evidence provided by other employees and contractors.

• May 7th: Appeal lodged by Al Zarooni against penalty imposed by Disciplinary Panel.
• May  9th: BHA announce that application has been received from Saeed Bin Suroor to take over as licensed trainer at Moulton Paddocks on a temporary basis. Godolphin are informed that the licence status of the yard will not change until test results from all horses are confirmed.
• May 20th: Results of the blood tests are announced showing an additional seven positives for stanozolol from horses stabled at Moulton Paddocks.

Encke
Energiser
Genius Beast
Improvisation
Stamford
Steeler
Zip Top

In line with the restrictions imposed on the 15 horses identified as having been administered anabolic steroids in the initial investigation, these seven horses are suspended from running in Britain for a period of six months from the date the samples were taken.

• May 20th: Saeed Bin Suroor is granted temporary licence to train from Moulton Paddocks as an additional yard
• May 29th: Al Zarooni withdraws appeal against penalty imposed by Disciplinary Panel.
• Jul 24th: Investigation is concluded and findings submitted to Godolphin
• Jul 25th: Results of investigation are published alongside the report provided to Godolphin

QUESTIONS AND ANSWERS

Why has the investigation report not been published in full?
The wider investigation into events at Moulton Paddocks was not a Disciplinary Panel hearing and the report which was compiled was always going to be confidential. Indeed, no report by any Investigating Officer into an investigation has ever been published; the contents are confidential and privileged and provide the basis on which BHA officials decide, among other things, whether to issue charges or not.

While we accept that both the circumstances and interest in this particular case are exceptional, that does not demand a change from the practice of not publishing reports compiled by Investigating Officers. As we have maintained throughout, the key findings from their report have been published, together with the full copy of the report sent to Godolphin.

In order to carry out an investigation successfully an element of confidentiality is required for those who are interviewed. Should any evidence have been uncovered that would have led the BHA to take action against any further individuals then this would have been disclosed in full as part of the disciplinary process.

Why was the decision made to act so quickly to remove Al Zarooni?
Once the BHA were in possession of sufficient information that proved that Al Zarooni was a corrupt presence within the sport it was imperative that he be removed immediately. To allow him to remain in the sport would have been to bring the sport into disrepute.

There is no indication that Al Zarooni would have provided any further evidence than that which was provided in his initial interview and his Disciplinary Panel hearing, and either way any information he did provide would need to have been corroborated elsewhere.

Who administered the substances to the seven extra horses?
The subsequent investigation was unable to ascertain with certainty how these horses came to be administered with prohibited substances. However, on the balance of probabilities and owing to an absence of any evidence to the contrary the views of the investigating officers of the BHA is that the administration of these substances was carried out by Al Zarooni in a similar manner to the earlier identified 15.

What was the involvement of Sharif Mahboob, Arvind Pillay and Sashan Jadhav?
The involvement of more junior members of the yard – Veterinary Assistant Sharif Mahboob and Foremen Arvind Pillay and Sashan Jadhav – has been detailed by the Disciplinary Panel and their findings are not disputed. It is clear that they were involved in the administering of prohibited substances to several horses, but were acting on the orders of Al Zarooni. They are not liable under Rules for their part in these events, and any personnel issues arising from this matter are the sole responsibility of Godolphin.

Why did you not interview Sheikh Mohammed?
Simon Crisford was interviewed on behalf of Sheikh Mohammed, in his capacity both as Racing Manager for Godolphin but also as an authorised representative of Sheikh Mohammed. Sheikh Mohammed is a Monarch of the state of Dubai who employs Simon Crisford to run his racing organisation, and as such it is Crisford’s role to represent him.

Had Mahmood Al Zarooni been the subject of testing in training previously?
Yes, testing in training was carried out at Moulton Paddocks within the last few years, without detecting any positive samples for prohibited substances.

How can you accurately establish when the steroids were administered?
It is impossible to establish the exact date on which any prohibited substance was administered. This is why the suspensions imposed upon those horses found to have tested positive are imposed from the date on which the samples were taken, as this is the only concrete date available.

However, we can gain an understanding of approximate timescales using interviews and some veterinary science, although this is unlikely to produce conclusive evidence.

For how long had Al Zarooni been using steroids?
While it is impossible to be 100% certain on this matter, our investigations did not uncover any evidence that Al Zarooni had been using anabolic steroids prior to this investigation.

Also, his yard was subject to testing in training prior to this investigation with no positive results, nor have any Al Zarooni-trained horses tested positive from raceday testing for anabolic steroids.

Are there any long term benefits for the horses in question which may give them an unfair future advantage in racing?
The science on anabolic steroids in horses is far from clear, substantially less so than in humans. It is feasible that horses will benefit from steroids for a period of time after the substance has left the horse’s system, however it is unlikely that these beneficial effects would last in perpetuity. This is why the BHA has made the decision to suspend all horses found to have been administered with anabolic steroids for six months.

Why is no further action being taken against Al Zarooni?
In view of the fact that Mahmood Al Zarooni had left the country and was not responding either to direct efforts to contact him or via his previously engaged solicitors, it was not considered the best use of the sport’s funds and resources.

The fact is he has been disqualified for eight years, but should he ever wish to work in British Racing again he would also need to satisfy a Licensing Committee that he is a suitable person. All of the evidence gathered from this investigation can be referred to as part of that process, including Al Zarooni’s reluctance to cooperate with the investigation in its later stages.

How do we know the use of steroids is not widespread in the sport?
Instances such as this are incredibly rare and there is no evidence at all to suggest that steroid use is widespread.

There has been only one other case of horses being intentionally ‘doped’ with anabolic steroids by a trainer in recent years, when veterinary records showed that trainer

Howard Johnson allowed horses to run under anabolic steroids in 2008 and 2009.

The presence of anabolic steroids in a horse’s system is prohibited at all times for any horse registered as ‘in training’ under the care of a trainer licensed by the BHA.

Do you do enough testing?
In 2012 over 8,500 horses were tested, either in training or on the racecourse. We have already indicated that the amount of budget and therefore numbers of tests carried out in training in 2013 will be substantially higher still.

Further to this, we are currently reviewing our anti-doping and medication control policy to ascertain whether the right amount of resource is currently being applied to this, and whether the balance of the manner in which that resource is deployed is correct.

If it is deemed necessary the BHA will seek additional funding through our annual budget process.

Why was Improvisation not tested after winning at Newmarket?
At this stage of the investigation by necessity a very small amount of people were aware of the situation, and the samples had not yet been confirmed as positive. This led to a gap between the testing in training and raceday testing procedures which subsequently led to this situation arising.

The BHA have addressed the procedural failings that allowed this to occur and as a result have amended the standard operating procedures to ensure this could not occur again.

Will Improvisation now be disqualified?
No. No objection has been lodged by any other parties in the race and as prescribed under the Rules of Racing the time for this has passed. Also, as no sample was taken on the day and the positive sample taken from Improvisation was done so well after the race in question it would be impossible to state with 100% certainty that the substances had been administered in advance of the race and thus that the horse would have tested positive on the day.

How will you police whether or not Godolphin act on the failings identified in your report?
We have already stated our intention to carry out both announced and unannounced visits of the Moulton Paddocks yard to carry out testing in training and monitor how the yard has progressed with the implementation of changes as a result of both the BHA’s and their own internal review.

The yard will be subject to enhanced monitoring for a period of time until the BHA is satisfied that a reduced level of scrutiny would be appropriate.