Policy Work

Policy responses

 
ENAR develops policy responses to EU legislative or non-legislative initiatives on a wide range of issues relevant to the fight against racism, from anti-discrimination and equality issues to social inclusion, education, migration and integration policies, and to fundamental rights.
 
 

  • EU Citizens' rights (June 2010)
    ENAR preliminary comments on the European Commission Working Document 'Consultation on EU Citizens' Rights - the way forward'





  • Socially-responsible public procurement (June 2009)
    Second contribution to the European Commission's Guide on Social Considerations in Public Procurement by a number of Belgian umbrella organisations representing women, ethnic minorities and people with a disability and supported by ENAR

  • Financial inclusion (April 2009)
    Comments of the Runnymede Trust and ENAR  to the European Commission consultation on "Financial inclusion: Ensuring access to a basic bank account"






  • Socially-responsible public procurement (January 2009)
    Contribution to the European Commission's consultation on a Guide on socially-responsible public procurement by a number of Belgian umbrella organisations representing women, ethnic minorities and people with a disability and supported by ENAR

  • New anti-discrimination directive (December 2008)
    ENAR preliminary position and proposed amendments on the proposal for a Council directive on implementing the principle of equal treatment between persons irrespective of religion or belief, disability, age or sexual orientation

  • Future of the EU Justice and Home Affairs area (December 2008)
    ENAR response to the European Commission's Consultation "Freedom, Security and Justice: What will be the future?". This consultation is part of the exchange of ideas that will lead to the definition of priorities in the area of Justice and Home Affairs for the period 2010-2014.







  • Employers' sanctions (April 2008)
    Common position of ENAR, PICUM and Solidar on the proposal for a directive on sanctions against employers of irregular third-country nationals

  • Active inclusion (February 2008)
    ENAR Response to the European Commission's Consultation on 'Modernising social protection for greater social justice and economic cohesion: taking forward the active inclusion of people furthest from the labour market'


ENAR has long been concerned with the question of education, both in terms of combating discrimination and racism in educational settings, as well as in maximising the potential of education to promote inclusive and equal societies. ENAR’s response highlights the key findings of ENAR members in the field of education and makes recommendations for action that ENAR sees as central to achieving the well being of ethnic and religious minorities within the European Union.


ENAR wrote this letter in advance of the Committee vote on the Draft Report on the proposal for a Council Framework Decision on combating certain forms and expressions of racism and xenophobia by means of criminal law (renewed consultation) by Martine Roure MEP, to express its views and support for key amendments that are proposed.


ENAR welcomes this opportunity to engage with the European Commission and other stakeholders. This is an important chance to move forward on the issue of gaps in protection under the European anti-discrimination law framework, building on and securing what is already there. It is also an opportunity to move the debate forward towards a fruitful discussion of how to take further action to address discrimination and inequality in the EU, building on the significant work already done by all stakeholders.


As a network concerned with the rights of all ethnic and religious minorities in the EU, ENAR is concerned that equality and non-discrimination are mainstreamed into European Asylum Policy, and are fully reflected in the Common European Asylum system.


ENAR strongly believes that if the 2010 European Year is to effectively follow-up the processes of the Lisbon Strategy and contribute to a decisive impact on eradicating poverty and social exclusion it must address the link between exclusion and discrimination. Similarly, addressing the impact of legal status on situations of exclusion is also of key importance, particularly in the case of migrants, refugees/asylum-seekers and Roma, Travellers and Sinti.



  • Policing (May 2007)
    ENAR’s comments on the draft ECRI General Policy Recommendation no. 11 on combating racism and racial discrimination in policing

Experiences of criminal justice (including policing), whether as employees, victims, perpetrators or witnesses, are key to the broader inclusion and integration of ethnic and religious minorities. ENAR supports the call for legal clarity regarding racial profiling and identifies the ECRI initiative to draft a general policy recommendation on racial discrimination in policing as an extremely important contribution to the debate in Europe.


This joint position was developed by Solidar, ETUC (European Trade Union Confederation) and PICUM (Platform for International Cooperation on Undocumented Migrants) in view of the forthcoming publication of a draft EU directive on sanctions against employers of illegally resident third-country nationals, and is supported by ENAR.


ENAR urges all the Member States of the European Union to move the fight against racism forward by adopting the proposed Framework Decision on Racism and Xenophobia under the auspices of the German Presidency.


In a letter to Commissioner Spidla ENAR responds to the European Commission Communication on the Application of Directive 2000/43/EC of 29 June 2000 implementing the principle of equal treatment between persons irrespective of racial or ethnic origin, published on 30 October 2006.

This response assesses the Commission’s evaluation of the first five year’s of implementation the ‘Race Directive’.


ENAR was invited to participate in the Social Inclusion Peer Review held in Aviles, Spain, 23-24 October 2006. The Network was represented by European Coordination member the European Roma Rights Centre (ERRC). In preparation for the Peer Review ENAR and the ERRC submitted a joint paper.

This paper outlines challenges to Roma integration policies in the European Union and among candidate countries. Specifically it addresses positive action, the adverse impact of legislation and policies, pervasive anti-Romani racism, lack of data, and the failure to address multiple forms of discrimination experienced by Roma.


In this joint amicus brief in the case of D.H. Others v. Czech Republic, ENAR with Minority Rights Group International (MRG) and the European Roma Information Office (ERIO), outlines concerns regarding segregation of Roma children in education and the need for measures to address structural and indirect discrimination across Europe.


In August 2006 the European Commission launched a ‘call for ideas’ for the proposed European Year for Intercultural Dialogue 2008. The call was facilitated through an online questionnaire which asked three specific questions relating to the ambition of the Year. This document contains ENAR’s response to each of the questions.


  • Education (October 2006)
    ENAR’s response to the preliminary draft text of ECRI General Policy Recommendation no. 10 on combating racism and racial discrimination at school

ENAR identifies the question of combating racism in the school environment and creating inclusive learning environments as critical.


  • Active Inclusion (April 2006)
    ENAR’s response to the Commission Communication concerning the consultation on promoting ‘active inclusion’ of people furthest from the labour market – COM (2006) 44 final

ENAR considers discrimination and racism against ethnic minority groups as main barriers to their integration to the labour market.


  • Integration (March 2006)
    ENAR’s response to the Commission Communication on A Common Integration Agenda, COM (2005) 389 final, and submission to the European Parliament Report on Integration

ENAR promotes a framework for the integration of third-country nationals in the European Union on the grounds of anti-racism and anti-discrimination.


ENAR considers fighting discrimination and promoting diversity core elements of cohesion policies, and the growth and jobs agenda.


ENAR concludes that Directive 2000/78/EC has increased protections against discrimination in employment, but is concerned that there remain substantial gaps in protection.


ENAR promotes the integration of migrants in the European Union as a tool for sustaining the link between migration and development.


ENAR welcomes the proposal to designate 2008 as European Year of Intercultural Dialogue and is concerned that it will contribute to the promotion of diversity and more inclusive societies.


ENAR estimates that Directive 2000/43/EC has increased protections against discrimination, but is concerned that there remain substantial gaps in protection.


ENAR, as a major outcome of 1997 European Year against Racism, is testament to the potential significance of initiatives such as the proposed 2007 Year of Equal Opportunities for All, which will provide a momentum in the fight against discrimination.


ENAR welcomes the proposal and is concerned that the momentum of the activities of the agency in the field of racism continues to be strongly encouraged and maintained.


ENAR considers this process to be a crucial opportunity for civil society to contribute actively to the development of this Agency focusing on fundamental and human rights.


  • Equality Green Paper (August 2004)
    ENAR Contribution to the public consultation on the Commission Green Paper on “Equality and Non-discrimination in an Enlarged Europe”

ENAR welcomes the Green Paper on the future of anti-discrimination policies as a well-timed initiative to respond to the new challenges of enlargement and to design the shape of future EU actions.


ENAR promotes a Europe of “inclusion” and of respect for the fundamental values of equality, fundamental rights and respect for diversity.


  • Family reunion (October 2002)
    ENAR’s response regarding the amended proposal for a Council Directive on the right to family reunion presented by the Commission – COM (2002) 225 final

ENAR considers the right to family reunion a fundamental human right and is concerned to protect equal rights for third-country nationals in the EU.


ENAR considers European citizenship to be a heart of the project on the future of Europe and calls for the recognition of the rights and obligations of European citizenship for all residents of the European Union, regardless their nationality.


ENAR supports the development of a common EU policy on immigration and promotes to improve the situation concerning discrimination and to establish equal rights of third-country nationals within the EU.


ENAR recognizes the Framework Decision as a unique opportunity to develop legal measures against racism and xenophobia.


ENAR expects the Durban conference to be an opportunity to achieve common goals and calls for concrete action plans at both national and international levels.


ENAR is concerned that the Charter should protect the 17 million third country nationals who reside legally in the 15 Member States.


ENAR’s position on the Council Decision

ENAR welcomes the idea of a Community Action Programme to combat discrimination in the EU, but also expresses a number of remarks.


ENAR has endorsed the Starting Line Proposal and notes a number of positive points, but also regrets the absence of some essential elements.

© Horus (Xtracms)