At the 3rd International Symposium on Drug Consumption Rooms [DCRs], held at the Council of Europe in Strasbourg, international professionals from a wide field of expertise gathered to discuss the role of these services within a human rights approach to drugs and drug use. This policy brief summarizes the day’s discussions to inform policy-makers on key topics and current developments in the field.
As part of the BOOST project, a Digital Skills Training for harm reduction organisations working in the area of HIV and viral hepatitis will be held between February and March. The course aims to build the capacity of community-based & community-led harm reduction organisations to use digital tools in the area of HIV and viral hepatitis services.
Find the course sessions, dates, and registration link for each session below:
Can’t attend all the sessions? Please note that joining only one of the sessions is also possible! You can register for each session you’re interested in separately through the respective link.
On 30 and 31 January 2024, partners of Correlation – European Harm Reduction Network and the BOOST Project met in Amsterdam to discuss the development of a European advocacy strategy to ensure access to comprehensive HIV, HCV and TB services for people who use drugs in Europe.
The development of a Joint European Advocacy Strategy is unique as it will be supported and implemented by 4 European Networks, including Correlation – European Harm Reduction Network (C-EHRN), the Eurasian Harm Reduction Association (EHRA), the European Network of People Who Use Drugs (EuroNPUD) and Drug Policy Network South East Europe (DPNSEE) and is based on a broad European consultation of nearly 100 experts and members of the different networks.
4-5 Advocacy Priorities and related Advocacy Objectives are identified during the Amsterdam meeting, covering the forthcoming 5 years (2024-2028). The final Strategy is expected to be launched and published in March 2024 and will be implemented with the support of a broader network of European harm reduction and drug policy organisations.
The Amsterdam meeting is part of a greater trajectory of the advocacy activities in the multi-annual BOOST Project. The results will feed into follow-up activities, including the organisation of Policy Webinars, a European Policy Dialogue Meeting during the European Harm Reduction Conference 2024 and the preparation of a series of Policy Papers.
In February, the networks will launch a call for local harm reduction services to support the development and implementation of Local Advocacy Plans in 6 countries/cities.
The Amsterdam meeting was co-organised by C-EHRN (coordinator of the BOOST Project) and EHRA, in close cooperation with EuroNPUD and DPNSEE.
On the 26th of January 2024, the Dealing with Drugs – Cities and the Quest for Regulation Conference took place in Amsterdam, marking a significant milestone in the global discourse on drug policy. The event not only delved into how further regulation of the drug market can address the effects of drug-related crime but also witnessed the launch of the Amsterdam Manifesto—an outset for a growing informal coalition expressing the wish for the next steps. Representing the Correlation – European Harm Reduction Network (C-EHRN) at the conference, Katrin Schiffer (C-EHRN director) contributed to the Closing Panel, highlighting the importance of establishing harm reduction initiatives at a local level as an entry point for the dialogue around drug policy reforms.
C-EHRN stands behind the Amsterdam Manifesto Dealing With Drugs and applauds Mayor Femke Halsema’s courage in openly acknowledging the need for a reevaluation of drug policy, which aligns with the sentiments shared by many policymakers worldwide, though often not addressed openly. The need for a more humane and evidence-based drug policy approach is clear, and by organizing the Conference and bringing together so many like-minded advocates, a first step has been made.
Acknowledging the critical importance of collaboration, C-EHRN sees the Amsterdam Manifesto as not merely a conclusion to the conference but rather the beginning of a promising coalition of the willing. This coalition is envisioned to grow over the coming years, uniting policymakers, politicians, civil society representatives, researchers and communities—including people who use drugs, people with lived and living experience. Together, they aim to shape a comprehensive and inclusive strategy for dealing with the complexities of drug-related issues.
C-EHRN is committed to this cause and will contribute to it by
C-ERHN encourages its members and partners to support the initiative by endorsing the Manifesto.
We are excited to launch Eliminating Hepatitis C in Europe: Report on Policy Implementation for People Who Inject Drugs! The publication is part of C-EHRN’s Civil Society-led Monitoring of Harm Reduction In Europe 2023 Data Report and focuses on the availability of and access to interventions that constitute the HCV continuum of care specific for people who inject drugs.
The report analyzes data from 35 European cities, provided by civil society organisations designated as focal points within the C-EHRN network. It assesses the impact of national strategies on HCV testing and treatment accessibility for people who inject drugs, examines the continuum of care across countries and cities, explores changes in the continuum of services over time, and highlights the role of harm reduction services in this context.
We asked Tuukka Tammi, programme director at the Finnish Institute for Health and Welfare and the primary author about the findings and how harm reduction organisations can use the report to advocate for their work at a city level. Download the report and read the interview below!
People who inject drugs are the main target group, if we use these words, for hepatitis C -related work. I don’t think that in any country only the specialized infectious experts could do enough in contacting, finding, treating them and keeping them in the treatment system.
Harm reduction services, services for the unhoused and all these low-threshold services are the only places where many of the people who use drugs are met, not anywhere else. This is also the case in Helsinki, where I come from. Even if we have quite a good general health care, many of the people who are hepatitis C positive don’t ever go there for one reason or the other. So I think harm reduction organisations are necessary partners for the healthcare system and infectious disease experts.
The hepatitis C testing & treatment guidelines are part of the questionnaire and the idea is to see the progress on the formal side of things. To be successful in hepatitis C work with people who use drugs, the country or the city needs to have formal guidelines so that these people are treated in a uniform way in different clinics. But we know that formal guidelines or instructions do not yet mean that the same happens in practice. So we also asked if they see contradictions or limited impact in practice.
Respondents reported many kinds of real-life impacts of these guidelines for testing and treatment and other services for people who use drugs. Mostly they say that these have a positive impact. They make hepatitis C-related work better in many ways, meaning people have better access to treatment and testing, and other positive impacts. Some mentioned that civil society organisations have better access to work with hepatitis C or are more involved because of the guidelines if these have an emphasis that low threshold services like harm reduction services should be included in the work.
Respondents from three cities from Eastern Europe believe that the guidelines had a negative impact. This mainly has to do, I think, with stressing in the guidelines that all hepatitis C-positive people need to be treated in specialized healthcare. We know it would be important to include harm reduction services in this work because people who inject drugs are often marginalized, often unhoused, and do not usually go to these specialised public healthcare settings.
One repeated missing thing was that undocumented migrants are not included in the guidelines. In practice, in many cities, there is no access to any testing or treatment services for them.
At the very general level, the interpretation from the past 4 years was that there is some positive development and also that this positive trajectory has been reestablished after the pandemic when the situation in many places got worse because of restricted opening hours and moving from face-to-face clinical work to some other forms of work.
Also on a very general level, it can be said that there is polarisation of European cities. In many cities, it seems that they are proceeding quite well and might even reach the global elimination goal for 2030, to eliminate hepatitis C totally or almost totally. Then there are cities where the progress is very slow and there’s a lack of many things like economic and political support for this work or advocacy, and insufficient infrastructure for testing and treatment in general. Some cities still have old-fashioned working methods, even the interferon treatment, which is not very effective and not very nice for the patient, but luckily this is quite rare.
Number 15. I think this is one of the main graphs from the viewpoint of harm reduction-related work, what kind of limitations are there for harm reduction organisations in addressing hepatitis C? This has been a more or less similar graph for many years. We see that there are 2 main obstacles: lack of funding and also lack of integration with the healthcare system. That’s a resource problem and a structural problem, not having links and connections.
10 cities mentioned a lack of staff doing testing and treatment, extra work in addition to other work they do. Then maybe the lack of recognition is related to the lack of integration with the healthcare system. Not everywhere are the harm reduction organisations regarded as relevant or qualified partners for doing this work. On the same level is a lack of political support, and there is a general weakness of local harm reduction services, they don’t have capacities to do this work. A lack of data for planning the work was also mentioned.
I think if we turn this into an advocacy or planning language, these are also the same factors that would need to be paid attention to.
There surely are good practices and good examples from many cities, how they are very well integrated, such as in Amsterdam, or in Barcelona where they also have an observatory for monitoring stigma in services.
The lack of funding and lack of political support is a more tricky one. It varies a lot, how the funding works in different cities. We know that for instance, in many Eastern European countries, there’s a general lack of or no funding for harm reduction services more generally, not only related to hepatitis C work.
One way to use it is to compare their situation with the others. If it’s worse than in other cities, making some noise about it in their cities and countries would be useful. Comparing different situations can also be an effective way to talk to policymakers. Not naming and shaming, but showing that harm reduction organisations can be very effective partners for the healthcare system in reaching people with hepatitis C and providing testing and treatment to them because we know that the prevalence of hepatitis C is most common among people who inject drugs and these people are not usually very well reached by the public healthcare system. So showing that this is possible, also in old fashioned systems where they still doubt that harm reduction organisations would be able to do this, showing from the example of other places that it’s working fine.
This report is hopefully useful for peer learning for some people. The more open and qualitative narratives in the report tell how things work in practice in different cities, which could be a source of inspiration for others. They could see what is happening in other cities and contact their colleagues from those cities to ask them for more detailed information: how does it work and how did they succeed in getting it done in the first place.
Following a new format, Correlation – European Harm Reduction Network’s Civil Society-led Monitoring of Harm Reduction in Europe 2023 Data Report is launched in 6 volumes: Hepatitis C Care, Essential Harm Reduction Services, New Drug Trends, Mental Health of Harm Reduction Staff, TEDI Reports and City Reports (Warsaw, Bălţi, Esch-sur-Alzette, London, Amsterdam). The Executive Summary can be accessed here.
The European Network of Drug Consumption Rooms [ENDCR] has elected the members of its Core Group! The Core Group comprises the Chairs of the different Work Groups, and its role is to strengthen the overall Network’s policy, strategic planning and activities.
Currently, the ENDCR counts the following Work Groups:
Five organisations that demonstrated outstanding qualifications, experiences and dedication were elected as members of the Core Group, to which they will all contribute. These are:
Ares do Pinhal | Portugal
Currently, Ares do Pinhal manage several harm reduction projects. These include a drug consumption room, access to screenings for communicable diseases, basic hygiene services, psychosocial support, wider healthcare, and a low-threshold methadone outpatient program. Additionally, they operate an emergency shelter.
Associació Benestar i Desenvolupament (ABD) | Spain
The ABD Group strives to defend people’s rights and personal autonomy in situations of social vulnerability, supporting them through different moments of their vital trajectories and taking action within their communities to promote social coexistence. Among other harm reduction projects, the ABD Group hosts Sala Baluard, a Drug Consumption Room in Barcelona.
Association Gaïa Paris | France
Gaïa Paris is an association that aims to improve the health of people who use drugs in Paris through services such as needle distribution, opioid agonist treatment, a drug consumption room, a mobile awareness and screening service for communicable diseases and liver fibrosis, and an integration programme.
CNDS Abrigado | Luxembourg
Abrigado is an organisation offering low-threshold health and social support to people who use drugs in Luxembourg. Their services include a drug consumption room, needle exchange programs, day centres, healthcare services, and emergency shelters.
Prindsen Reception Centre | Norway
The Prindsen Reception Centre is a low-threshold health and social care service that aims to prevent harm and offer support based on individual needs to people who use drugs. The centre hosts a drug consumption room and provides counselling, sterile harm reduction equipment, and other healthcare and support services.
The next steps include the organisation of the first meeting of the newly established Core Group, in which the responsibilities of WG Chairs will be distributed among the elected organisations.
[The European Network of Drug Consumption Rooms [ENDCR] is a membership-based civil society platform uniting organisations operating or planning to implement a Drug Consumption Room [DCR] in Europe. Its goal is to enhance the availability, accessibility and quality of these services. Hosted and coordinated by Correlation – European Harm Reduction Network [C-EHRN], the ENDCR is governed by a Core Group and channels its activities through various thematic Work Groups.]
To mark the publication of The Mental Health Challenges Faced by Harm Reduction Staff, we invite you to join the webinar on the 15th of February!
The publication is a segment of Correlation – European Harm Reduction Network (C-EHRN)’s Civil Society-led Monitoring of Harm Reduction In Europe 2023 Data Report and is dedicated to the well-being and working environment of harm reduction staff. The study focuses on the various challenges harm reduction workers encounter in their work and how those challenges affect them and their organisations, as well as coping mechanisms and organisational opportunities for support.
The participants in this study are identified as focal points within the C-EHRN. The network encompasses a diverse array of contributors, including grassroots and community-based organisations, service providers, drug user organisations, and research entities. Within this network, focal points act as hubs for collecting data and information on a broad range of issues related to harm reduction in the cities they work.
During the webinar, 3 representatives of the participating focal points will join the primary author, Laoise Darragh, to discuss the findings.
Panellists:
Laoise Darragh (C-EHRN)
Magdalena Bartnik (Prekursor Foundation for Social Policy, Warsaw, PL)
Martin Blakebrough (Kaleidoscope 68 Project, Newport, GB)
Tessa Windelinckx (Free Clinic, Antwerp, BE)
To join the webinar, register by the 14th of February on this link.
Following a new format, Correlation – European Harm Reduction Network’s Civil Society-led Monitoring of Harm Reduction in Europe 2023 Data Report is launched in 6 volumes: Hepatitis C Care, Essential Harm Reduction Services, New Drug Trends, Mental Health of Harm Reduction Staff, TEDI Reports and City Reports (Warsaw, Bălţi, Esch-sur-Alzette, London, Amsterdam). The Executive Summary can be accessed here.
On 24 January, European civil society sent an open letter to the Presidents of the European Commission and the European Parliament, and the Belgian presidency of the Council of the European Union. The signatories of the letter urge the three main institutions of the European Union (EU) involved in EU decision-making to take concrete measures to implement an open, transparent and regular dialogue with civil society organisations in all policy areas, as set out in Article 11 of the Treaty on European Union. The open letter was initiated by the Civil Society Organisations’ Group of the European Economic and Social Committee (EESC) and Civil Society Europe and includes specific proposals for implementation. The letter gained the support of a total of 156 signatories from 26 Member States. The signatories include 39 European networks, 85 national organisations and 60 Members of the EESC’s Civil Society Organisations’ Group (1).
Civil dialogue remains patchy and unstructured across the EU institutions, in spite of the legal provisions.
This is why the signatories of the open letter #EUCivilDialogueNow are calling on the EU institutions to:
building on the recommendations of the Conference on the Future of Europe.
As a first step, the signatories suggest a European Commission Communication on strengthening civil dialogue at the EU level.
“The European institutions have all the necessary tools to make considerable progress on our proposals,” said Séamus Boland, the President of the EESC’s Civil Society Organisations’ Group, on the eve of the letter’s launch. “In the next European Commission, a vice-president should take on the task of dialogue with civil society, and civil society coordinators should be appointed in each directorate-general,” added Mr Boland.
Gabriella Civico, the President of Civil Society Europe, said: “The Secretariat of the Council of the EU and the offices of the European Parliament and Commission at the national level need to establish a regular dialogue with civil society. Civil society organisations need direct channels to engage in the EU policy-making process.”
While the signatories respect the prerogatives of the social partners in social dialogue, they are calling for structured civil dialogue to complement it. Séamus Boland explained: “Effective and responsible civil society organisations can cooperate with governments and with employers’ and workers’ organisations in many areas of policy. The input of their knowledge and expertise can ensure that EU policies in all fields and on all socio-economic issues are more targeted and effective.”
Gabriella Civico concluded: “Real civil dialogue and cooperation will lead to EU policies better securing the support of citizens and gaining more legitimacy in their eyes, and thus ensure smoother policy implementation. This is particularly important in a complex and rapidly changing world with many challenges that our communities and societies need to address.”
Background information:
The European Economic and Social Committee (EESC) is a consultative body established by the 1957 Treaty of Rome. It assists the European Parliament, the Council of the European Union and the European Commission. The EESC is the voice of organised civil society in Europe. It represents employers, workers and civil society organisations. The expertise of its 329 Members helps optimise the quality of EU policies and legislation. The EESC’s Civil Society Organisations’ Group is made up of 106 “other representatives and stakeholders of civil society, particularly in the economic, civic, professional and cultural field”.
Its Members are drawn from organisations representing the following fields:
The overall aim of the Civil Society Organisations’ Group is to truly strengthen participatory democracy across the European Union and to make sure that EESC opinions on EU legislative proposals reflect the interests of all Europeans.
Civil Society Europe (CSE) is the coordination of civil society organisations at EU level established in February 2016. It brings together 22 European networks of civil society organisations (CSOs) working towards regenerating the European project around the shared values of equality, solidarity, inclusiveness and democracy. Its main objectives are: to facilitate and enable horizontal and vertical dialogue between European civil society organisations and policy-makers and help strengthen CSOs in their activities and relations with the institutions.
CSE’s mission is to contribute to EU recognition of the essential role and value of independent and plural CSOs in building and nurturing a democratic society that is based on fundamental rights. CSE also works to create the conditions for the development of a strong and independent civil society voice and effective, open, and structured civil dialogue at the EU level, as well as a thriving and enabling civic space across the Union.
For more information and interviews, please contact:
Jasmin Klötzing
Communication Officer
Secretariat of the Civil Society Organisations’ Group
+ 32 (0) 2 546 90 67
Jasmin.kloetzing@eesc.europa.eu
Margarida Reis
Communication Assistant
Secretariat of the Civil Society Organisations’ Group
+ 32 (0) 2 546 90 36
Margarida.reis@eesc.europa.eu
If you want to stay informed about the activities of the Civil Society Organisations’ Group, please click here.
(1) When calculating the number of signatories (156), the EESC Members who also signed on behalf of their organisation are counted as single signatories.
We are excited to announce an open call for trainers for Project CORE‘s Workshop Series!
Responsibilities:
For detailed information, read the Terms of Reference!
To apply, please fill in this online form.
You can apply as a trainer for more than one topic.
Looking forward to receiving your applications!
We, the undersigned organisations, are deeply concerned about the drastic intensification of anti-drug operations in Sri Lanka leading to significant human rights violations.
On 17 December 2023 the Acting Inspector General of Police Deshabandu Tennekoon, with the endorsement of Minister of Public Security Tiran Alles, spearheaded an operation titled “Yukthiya”, with the stated aim of controlling “the drug menace”. The operation is ongoing as of 10 January 2024, with at least one thousand persons arrested daily.
This operation is unfolding in a context of already severe repression against persons who use or are suspected of using drugs, who suffer discrimination and stigma within the Sri Lankan criminal justice system and society.
Alongside the Sri Lankan police, members of the armed forces have been supporting this operation,[1] during which several human rights violations have been reported.[2] These violations include alleged arbitrary arrests, primarily against individuals from marginalised socio-economic communities; searches conducted without warrants or reasonable suspicion; and, degrading treatment including strip searches in public as well as cavity searches. The searches and arrests have been televised,[3] in violation not only of the right to privacy (and of basic human dignity) but also of a person’s right to be presumed innocent. According to lawyers, persons are being arrested even when no drugs are found in their possession, simply for having been arrested for drug offences or having been sent to compulsory rehabilitation in the past. The arrests of main livelihood earners and mothers have adversely impacted the ability of families to meet their basic needs during a time of economic crisis in Sri Lanka, and the wellbeing of children.
Persons are being arrested primarily under Section 54A of the Poisons, Opium and Dangerous Drugs Ordinance, an offence which is non-bailable. As a result, those arrested are bound to spend time (sometimes months) in pretrial detention, thereby exacerbating already poor conditions of imprisonment in an overburdened prison system.[4] The Human Rights Commission of Sri Lanka has previously stated[5] that the existing prison conditions and treatment of incarcerated persons are ‘inhumane and degrading’. At present, as per statistics issued by the Department of Prisons, the level of overcrowding of the prison system is at nearly 200% – with punitive drug policies playing a significant role: as of 2022, 63% of convicted persons were sentenced for drug-related offences.[6]
The total reported number of arrests pursuant to operation Yukthiya has exceeded 29,000 as of 9 January 2024,[7] while nearly 1,500 people are in administrative detention in police custody for further investigation.[8] At least 1,600 more persons have been sent for compulsory drug rehabilitation,[9] in violation of several fundamental rights, including the right to the highest attainable standard of health, which includes the right to consent to and withdraw from medical treatment. “Drug treatment” in these centres is abstinence-based, essential harm reduction services are not available,[10] and persons undergo severe withdrawal symptoms without any medical assistance while in detention. The use of violence to discipline and punish[11] has been reported in at least two compulsory drug rehabilitation centres which are within the purview of the Bureau of the Commissioner General for Rehabilitation and are operated by the military,[12] which is in itself a violation of international standards.
The UN Working Group on Arbitrary Detention in its statement at the conclusion of its visit to Sri Lanka in 2017[13] expressed concern regarding the involvement of military personnel in drug treatment and rehabilitation. It expressed concern that strenuous physical exercise was the core component of compulsory drug treatment, and at the lack of trained professionals to monitor the health of people in detention. Furthermore, the statement highlighted the irregularities in the judicial process by which persons were sent to the centre without a medical assessment being carried out.
More broadly, the UN Special Rapporteur on Torture has highlighted that by denying persons access to substitution therapies, states are subjecting “a large group of people to severe physical pain, suffering and humiliation, effectively punishing them for using drugs and trying to coerce them into abstinence.”[14] The Special Rapporteur has further stated “forcible testing of people who use drugs without respecting their autonomy and their right to informed consent may constitute degrading treatment, especially in detention settings. States are obliged to respect the enjoyment of the right to health, including by refraining from using coercive medical treatment. The requirement of informed consent, including the right to refuse treatment, should be observed in administering any treatment for drug dependence.”[15]
Since the 2016 UN General Assembly Special Session on drugs, there is international consensus on pursuing a holistic and health and human rights-based approach to drugs, which encompasses supply and demand reduction as well as harm reduction. The 2019 Ministerial Declaration on drugs – the current global drug policy document – as well as multiple resolutions of the UN General Assembly, the UN Commission on Narcotic Drugs, and the UN Human Rights Council reiterate and recommend a similar approach.
A punitive and militarised approach to drug control contravenes recognised international human rights standards and guidelines, is ineffective to protect individual and public health, and ultimately fails to make communities safer.
We call upon the government to:
The co-signatories:
[1] ‘Operation ‘Yukthiya’: 1,184 more suspects arrested with drugs’ Ada Derana, 5 January 2024. https://www.adaderana.lk/news.php?nid=96159
[2] ‘HRCSL concerned over alleged human rights abuses in ’Yukthiya’ Operation’ Daily Mirror, 8 January 2024.
https://www.dailymirror.lk/breaking-news/HRCSL-concerned-over-alleged-human-rights-abuses-in-Yukthiya-Operation/108-274667
[3] ‘Operation Yukthiya: Over 18,000 suspects arrested since launch’ News First, 30 December 2023.
https://www.youtube.com/watch?v=-6vdBuEH4dw
[4 Ambika Satkunanathan (2021) ‘Broken System: Drug Control, Detention and Treatment of People
Who Use Drugs in Sri Lanka’ Harm Reduction International.
https://www.hri.global/files/2021/08/03/HRI_Report_Sri_Lanka_Drug_Control.pdf
[5] Human Rights Commission of Sri Lanka, Prison Study by the Human Rights Commission of Sri Lanka, 2020,
https://www.hrcsl.lk/wp-content/uploads/2020/01/Prison-Report-Final-2.pdf.
[6] Department of Prisons (2023) Prison Statistics 2022. http://prisons.gov.lk/web/wp-content/uploads/2023/05/prison-statistics2023.pdf
[7] “Operation Yukthiya Nets Over 29,000 Suspects in 22 Days” News First, 8 January 2024.
https://www.newsfirst.lk/2024/1/8/operation-yukthiya-nets-over-29-000-suspects-in-22-days
[8] Ibid
[9] ‘Yukthiya’ operation leads to 28,520 arrests’ Daily Mirror, 8 January 2023. https://www.dailymirror.lk/print/front-page/Yukthiyaoperation-leads-to-28-520-arrests/238-274623
[10] Ambika Satkunanathan (2021) ‘Broken System: Drug Control, Detention and Treatment of People
Who Use Drugs in Sri Lanka’ Harm Reduction International.
https://www.hri.global/files/2021/08/03/HRI_Report_Sri_Lanka_Drug_Control.pdf
[11] For narratives of persons who have been sent to compulsory treatment centres please see ‘A collection of personal narratives of
persons who use drugs in Sri Lanka (2024)’ compiled by Ambika Satkunanathan at
https://drive.google.com/file/d/1WJdgrObqMd62aGdXchG7y5lcvI0zlNeP/view
[12] Ibid
[13] Working group on arbitrary detention: preliminary findings from its visit to Sri Lanka (4 to 15 December 2017).
https://www.ohchr.org/en/statements/2017/12/working-group-arbitrary-detention-preliminary-findings-its-visit-sri-lanka-4-15
[14] ‘Report of the Special Rapporteur on Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment’ (UN Human
Rights Council, 1 February 2013) https://www.refworld.org/docid/51136ae62.html.
[15] Ibid
