ࡱ> Y `bjbjWW ==E]****8bvl*">>>kmmmmmm$\Pb>>>>k**k"'  k>$.m**"/< Save the Children response to European Commission working document: Towards common standards on asylum procedures A response from the Save the Children Europe Group representing International Save the Children Alliance members in Europe, and the Separated Children in Europe programme, a partnership between Save the Children and the United Nations High Commission for Refugees Further copies available from:- Diana Sutton European officer Save the Children European office 1 Place du Luxembourg B 1050 Brussels Belgium Tel : + 32 2 512 7851 Fax + 32 2 512 6673 E mail  HYPERLINK "mailto:savechildbru@skynet.be" savechildbru@skynet.be July 1999 Towards common standards on asylum procedures Realising the rights of children A response from the Save the Children Europe Group representing International Save the Children Alliance members in Europe, and the Separated Children in Europe programme, a partnership between Save the Children and the United Nations High Commission for Refugees Save the Children context Save the Childrens mission is to work for the realisation of childrens rights world-wide through advocacy and the delivery of practical programmes of action. Save the Children uses the UN Convention on the Rights of the Child 1989 as a framework for all its actions. We welcome this opportunity to respond to the Commissions consultation document Towards a Common Asylum Procedures in particular as it affects children. Save the Children hopes to be able to engage in continued dialogue with the Commission on this important area of developing Community policy. The Europe Group is an regional grouping of Save the Children agencies in EU, EFTA and Central and Eastern European countries who work together to ensure that childrens rights and integrated in all relevant European policy developments and on programmatic co-operations within the region. Save the Children members and the Europe Group are working actively with a number of different Directorates of the European Commission, including work on child trafficking and sexual exploitation (Secretariat General, under the Daphne programme), with DG VIII and DG 1B (children in EU development policy), DG V (childrens rights) and ECHO. Save the Children has much experience from direct engagement with refugee children in many conflict zones over the last 80 years and in meeting the needs of refugee children within Europe. Examples of our work include programmes to facilitate the return of refugee children to their home country and research on the quality of legal assistance available to separated refugee children. Save the Childrens work on refugees has included work in every continent, beginning with a response to refugee children in the Balkans in 1919, including direct assistance to refugee populations, initiation of targeted programmes of action in response to specific needs, research and advocacy. Examples of programmatic work include providing material assistance, core educational activity for children living in the camps, family tracing, pyscho social programmes, health care. Specific programmes have also been developed to respond to the situation of children who have become separated from their families. Save the Children organisations have developed materials that can be rapidly deployed in any new conflict situation in order to facilitate early intervention to reunite children as quickly as possible. The Separated Children in Europe Programme, a partnership between Save the Children and UNHCR funded by the EU Odysseus Programme is a topical example of this approach. Introduction Save the Children welcomes the attention that has already been given by the European Commission and the member states to the issue of unaccompanied children, in particular the standards set out in the soft law in the Council resolution of date of 26 June 1997 on unaccompanied minors. Save the Children welcomes the comment in paragraph B.6 of the document which states that asylum must be compatible with the key international refugee and human rights instruments. A full list of what we believe to be the relevant instruments is given in Appendix 2 to this paper. We would emphasise the UN Convention on the Rights of the Child, the most ratified of all international instruments and which provides the firm foundations on which our work is based. In particular we would emphasise the general principles in the Convention on the Rights of the Child, promoting the best interests of the child, non discrimination, survival and development and participation and we would stress that these apply to all children. The UN Convention on the Rights of the Child should inform all actions concerning children, particular attention should be paid to Article 3: The best interests of the child, Article 12: The participation of the child in decisions affecting them and Article 22 on Refugee children. Why Consider Children Specifically ? Save the Children has recommended in Towards an EU Human Rights Agenda for Children (1998) that all relevant EU policy, programmes and legislation need to be child proofed against the standards in the UN Convention on the Rights of the Child 1989, which has been ratified by all member states. In Save the Childrens experience because of the lack of any specific legal base in the Treaty of Amsterdam to promote and protect the rights of children, childrens needs and interests tend to get overlooked at the drafting stage of much EU legislation. Furthermore because of childrens lack of status in the Treaty of Amsterdam and the lack of clarity of childrens legal status at EU level and indeed at national level, it is vital that legal instruments contain specific provisions to promote and protect the rights of children. It is our experience that children are not always covered by adult based measures. Therefore Save the Children recommends that children both those who are with their families and those who have become separated from their families should be explicitly mentioned throughout the Directive. In addition to integration of childrens needs throughout the text, a specific section should be included to cover the needs and rights of children. In contributing to EU policy on asylum Save the Children argues for specific measures to protect refugee children and to realise their rights because of: The large proportion of children in refugee populations Children being separated from their parents According to the recent UNHCR report State of the Worlds Refugees (97/98) more than 50% of any refugee population are children, and in large population movements this percentage will usually increase. Policies which are intended to address the needs of the whole population of refugees need therefore to specifically recognise and target the needs of children. Save the Children has a particular concern for children who become separated from their parents during their flight from conflict, persecution etc. Experience through many conflict situations has shown us that this phenomenon is something that we should anticipate as an inevitability of population movements. The term unaccompanied minors has been used to describe this group of children for many years, but as population movements have become more frequent, and of a larger scale, the terminology has begun to change. Many children begin their journeys accompanied by other members of their family, or with family friends and experience has shown that once settlement for these temporary carers becomes possible, the cared for child becomes abandoned and is then unaccompanied. In recent years organisations engaged with these children have encouraged the use of the term separated children in order to ensure recognition of the significance of the childs separation from her/his parents thereby encouraging appropriate responses to their needs and hopefully avoiding them becoming unaccompanied. It is for this reason that the title Separated children in Europe has been used for the partnership programme between UNHCR and Save the Children. (Appendix 3 contains a fuller definition). Finally asylum procedures must make the distinction whether the asylum applicant is under or over 18. If they are under 18 checks and safeguards must be built into law which are additional to standards applying to adults. In this response, Save the Children concentrates on two areas, first the specific safeguards that we believe are necessary within the legal framework to protect and realise the rights of separated children, and secondly more general comments on some of the issues raised in the consultation document. This paper illustrates why it is necessary to recognise the distinctive rights of refugee children in their own right, and draws on the international instruments which we believe must inform policy and practice (see Appendix 2). Recommendation: Save the Children recommends that children both those who are with their families and those who have become separated should be explicitly mentioned throughout the Directive, it is our experience that so often in legal texts the lack of a reference to children leads to their needs being ignored. In addition to integration of childrens needs throughout the text, a specific section should also be included to cover the needs and rights of children. Key issues in the Commission discussion paper C.1 Broad Approach Prescriptive Approach versus General Approach As member states have agreed in the Treaty of Amsterdam that asylum policy will move from the third pillar to the first pillar, it is inevitable that harmonisation will take place. It therefore important to ensure that this takes place at a level which offers the highest possible protection to children. For the reasons outlined, below, Save the Children believes that it is important that the legal instrument ensures enforceable minimum standards for children regardless of where they are seeking asylum in the EU and that it promotes the bests interests of the child. We would stress that any legal instrument should contain a high level of safeguards as a minimum standard, so that the lowest common denominator is not ruling the instrument. Member states have already agreed a number of minimum standards in non binding soft law of regulations, we therefore believe that it is the appropriate time for a legal instrument which raises and implements the standards of non binding inter governmental instruments. It is our experience that despite all member states having ratified the UN Convention on the Rights of the Child, and despite the Convention clearly stating that it applies to all children (whether resident or non resident) children seeking asylum receive very different treatment depending on which member state they apply for asylum in. Save the Children is aware of at least two cases where NGOs have used the Convention as a legal instrument to prevent a child asylum seeker being deported and one case where the member state has revised its law. In 1997 the Swedish Aliens Act was modified to be more in accordance with the provisions of the CRC. The principle of the best interests of the child is now incorporated as is the right of the child to be heard. This would suggest that it is necessary to place very clear legal obligations on member states to ensure that children seeking asylum have the same treatment regardless of which member state they seek asylum in (precise standards on this are set out in more detail below). A common legal framework should reflect the highest levels of implementation of the UN Convention on the Rights of the Child. Save the Children supports the approach outlined in the consultation paper to commission a study with a view to establishing a common European asylum procedure. Because of childrens particular vulnerability and particular lack of status as legal entities, Save the Children would like to stress that the proposed study looks specifically at important issues which affect children. For example:- the extent to which member states have implemented the Council resolution on unaccompanied children and have amended national laws to ensure implementation of relevant articles concerning refugee children in the Convention on the Rights of the Child, the effects of fingerprinting on children (see below under Eurodac). An exploration of the relevance of the 1951 Convention to the current situation of population movements into and across Europe with particular reference to child specific forms of persecution such as sexual exploitation, child conscription and child labour (Save the Children is carrying out its own study financed by the EU Odysseus programme into the reasons why children move, we hope that this will provide useful information to inform the debate about harmonisation.) An exploration of good practice in relation to the care and protection of children who are separated from their parents (Save the Children would be happy to contribute to this from its own research) An exploration of the mechanisms necessary to retain family unity, and to effect family reunification when families are divided between a number of countries in the European Union or European Economic Area Council Resolution on Unaccompanied Children (June 1997) Save the Children welcomed the Council Resolution of 26 June 1997 on Unaccompanied minors who are nationals of third countries" as an important political commitment by the member states to realising the rights of separated children. We underline that this resolution represents existing soft law and like the other resolutions referred to in paragraph 10 (Scope of the proposal, the existing soft law), should also be used as a starting point in preparing a proposal for a Community legal instrument. In general the Council resolution is a useful document which we welcome, however there are a few articles which cause us concern which we would wish to see changed in any primary legal framework. First, the resolution lacks integration of and reference to the best interests of the child principle. Secondly, Article 2 in the resolution, states that member states may refuse admission at the frontier to unaccompanied minors and may keep them at the border until a decision has been taken on their admission. Save the Children believes that separated children seeking protection should never be refused entry or returned at the point of entry and should never be detained for immigration reasons. Neither should they be subject to detailed interviews by immigration authorities at the point of entry. At ports of entry immigration authorities should put in place procedures to identify separated children and young people. Where children are accompanied by an adult, it will be necessary to establish the nature of the relationship between the child and adult. Since many separated children enter a country without being identified as separated at ports of entry, organisations and professionals should share information in order to identify separated children and ensure they are given appropriate protection. This is reinforced by international human rights instruments (see statement of good practice for references). In addition, registration and documentation are essential to protect the long-term interests of separated children. This should be carried out by a twin-track interview procedure once a guardian/adviser has been appointed. Immigration and border police officers should limit their interviews to gathering basic information about the childs identity. All those interviewing separated children should have appropriate training or expertise. Save the Children, as part of the Separated Children in Europe project, funded by the European Commissions Odysseus programme has prepared a statement of good practice, which is enclosed for reference. This statement details specifically many of the areas which are covered by the Council resolution and we believe the key principles of the safeguards outlined in our statement and in the resolution should now be incorporated into community law. In particular:- Appointment of Guardian or Adviser As soon as a separated child is identified, a guardian or adviser should be appointed - in a long-term perspective - to advise and protect separated children. Regardless of the legal status of this person (eg. legal guardian, NGO worker) their responsibilities should be as follows, to ensure that all decisions taken are in the childs best interests, to ensure that a separated child has suitable care, accommodation, education, language support and health care provision, to ensure a child has suitable legal representation to deal with her or his immigration status or asylum claim, to consult with and advise the child or young person, to contribute to a durable solution in the childs best interests, to provide a link between the child and various organisations who may provide services to the child to advocate on the childs behalf where necessary, to explore the possibility of family tracing and reunification with the child. In order to ensure necessary protection for separated children, appointments of guardians/advisers should be made within one month of a child being notified to the relevant authorities. The individuals carrying out these responsibilities may be drawn from a range of specialist backgrounds. However, in order to carry out their role effectively, advisers or guardians must have relevant childcare expertise and an understanding of the special and cultural needs of separated children. They should receive training and professional support. Interim care Separated children and young people should be found suitable care placements as soon as possible after arrival. Care authorities should conduct a careful assessment of their needs, and changes in care arrangements should be kept to a minimum. Siblings should be kept together. Where children live with or are placed with relatives, these relatives should be assessed for their ability to provide suitable care. Separated young people over 16 years of age should not be treated as defacto adults and placed on their own, without adult support, in hostel or reception centre settings. Whether they are placed in foster care or in residential settings separated children should be cared for by suitable professionals who understand their cultural, linguistic and religious needs. Care workers should help a child develop links with their ethnic community where such exists. Regular reviews of care arrangements should be carried out. Age Determination We would argue that there should be a commitment establishing common standards for age determination for children who are separated from their parents, and are identified as such on or subsequent to arrival in a member state.. The Separated Children in Europe programme has made a specific submission on this point some time ago. We reiterate our commitment to the comments contained in that paper, and for ease of reference attach it as Appendix 1 to this paper. Trafficking In order to establish safeguards, care workers in reception centres and residential homes need to be made aware of the problem of trafficking of children and young people for the purposes of prostitution or other forms of exploitation. The Treaty of Amsterdam : a work programme on Asylum and protection issues Save the Children now comments on other areas in the Commissions document and in particular to section B.5. which lists eight topics into which the legislative programme on asylum and protection can be divided. (1) Determination of which state is responsible for considering an application for asylum In general Save the Children agrees with the position by ECRE (European Council on Refugees and Exiles) on refugee children. However there are some specific issues which particularly affect children who are separated from their families which we elaborate below. We believe that a separated (unaccompanied) child should never be sent to a third country without investigation into why she/he is in the asylum country. However, we would also wish to re-emphasise in this section the importance of European States agreeing, and putting into place, mechanisms which will facilitate speedy family reunification for those families who are divided between different European States. Such reunification should be effected in the state where the childs best interests will be met, and consistent with the childs own opinion. It is important that the states concerned find flexible solutions with the principle of the best interests of the child as a guiding rule. There can of course not be an exact definition of what the best interests of the child is. It must be determined in each case but the principle of the best interests of the child should be taken into account for example when the child is going by plane from UK to his/her parents in Germany when planning how the trip will be organised; who will accompany the child, who will meet the child etc. These comments are also relevant to point B.8 on promoting a balance of effort. (2) Eurodac The Eurodac Convention stipulates that Member States will take fingerprints of every applicant for asylum of at least 14 years. This is despite the fact that the UN Convention on the Rights of the Child defines the age of majority as 18 years. We are concerned that taking the fingerprints of children who may have experienced significant trauma may doubly traumatise and stigmatise child asylum seekers. We are also concerned about what procedures will be used in the event that a child is suspected of fraud, given differing definitions of the age of criminal responsibility and different juvenile justice systems in the member states. We do have concerns about how this will operate and would recommend that this is examined in the Commissions study. (3) Minimum standards on the reception of asylum seekers The health and educational needs of refugee children are of paramount importance, whether they arrive with their parents, or are separated from them. We stress the importance of these provisions at the point of reception, since for a child any weeks or months lost to education can take many years to recapture, and lack of access to appropriate health care can also have long term affects on the childs long-term growth and development. Article 2 of the CRC stipulates that the States Parties shall respect and ensure the rights set forth in the CRC to each child within their jurisdiction without discrimination of any kind. This is particularly important regarding the right to health care and education. It is also important that children receive psychosocial support, (according to Article 39 in the CRC.) We also elaborate further in the statement of good practice some minimum standards. (5& 6) Minimum standards with respect to qualification, granting or withdrawing refugee status, for complementary/subsidiary protection for persons in need of international protection and the provision of temporary protection. A child should have right to seek asylum. A child may have grounds for seeking asylum in his/her own right and should be entitled to an individual determination of his/her application. It is important that the staff of the immigration authorities have specific knowledge of children's rights and needs. There must be special training courses for these staff. Additional issues Safe Third Country concept and Admissibility A separated child should be exempted from all accelerated procedures, such as safe third country procedures. If a separated child is sent away to another country anyway, the child must be given a document saying that the child's application for asylum has not been examined and the state must ensure that child will be granted a fair and efficient asylum determination procedure. Speeding up procedures Separated children should be given priority in the determination process but this should not be an accelerated procedure. The rule of law and the safeguards must be respected during the whole process. Response prepared by:- Diana Sutton- European officer - International Save the Children Alliance David Wright Advisor Separated Children in Europe Programme Christina Heilborn Legal Advisor - Rdda Barnen Appendix 1 AGE ASSESSMENT This note draws on the experience of non-governmental organisations who are involved with the Separated Children in Europe programme, a partnership between the International Save the Children Alliance and UNHCR. Age assessment is one of the most crucial issues in dealing with the cases of separated children because for those who are considered incorrectly to be adults, the implications in terms of their asylum applications, detention, care etc will lead to the denial of their fundamental rights under the UN Convention on the rights of the Child. However, the network is well aware that applications are made by people claiming to be aged over 18 years, when they are in fact some years older. In some countries the scale of this abuse is of concern to members of the network since the implications of the abuse are that authorities will be inclined to make the controls even more stringent, thus further denying the rights of those aged below eighteen years who are in need of, and have the right to, the full protection of the UN Convention on the Rights of the Child in addition to other appropriate Conventions and statutes. The Separated Children in Europe programme is therefore of the view that the European Union should be insisting that member governments only apply those age assessment measures which have proven validity and are widely respected by appropriate professional bodies. This would mean that reliance on radiological examination should be excluded from future practice. The following quotes are from a UK consultant paediatrician of 30 years standing: Bone Age is assessed by comparing the stage of several key examples of the X-rays of growing ends of the subjects bones, with atlases of the findings in a large sample of health individuals. The only reliable Atlases refer to those of European descent. The reselects are expressed as a bone age in years. This is a mean value and would be appropriate for a healthy individual whose chronological age was within two years above or below the figure given. the report I have received from Dr. X of the Institute of Child Health who kindly reviewed Ys X-rays.the scoring system he used makes no allowance for racial background. These comments are further reinforced by the following quotation from The Royal College of Radiologists: Fellows and members are advised that it remains inappropriate to undertake a radiographic examination at the request of an immigration official, or the like, for the purposes of bone age estimation. Whilst an individual may request a radiograph for their own purposes, the limitations on the accuracy of the radiograph are such that the College recommends considerable circumspection before acquiescing to such a request. Whether or not such a radiograph may be regarded as a medical or not the principles contained within the Ionising Radiation (Protection of Persons Undergoing Medical Examination or Treatment) Regulations 1988 still apply. Hence the estimation of bone age for purposes of asylum or immigration does not constitute accepted practice. Evidence we have received from other European countries Italy, France and Holland would suggest that these views are widely shared, and further that any age assessments that are carried out should only be on the basis of thorough paediatric examination that takes specific account of gender, culture and ethnic issues. As suggested above, given he significance of age assessment in terms of the potential denial of rights to a child, we would further argue that the following definition should be adopted: A child means a person who is under 18 years of age, or who, in the absence of documentary evidence, appears to be under that age. Finally therefore I would refer you to page to page 5 of our programmes Statement of Good Practice on this issue which summarises who view on the most appropriate position to be adopted and indicates where appropriate reference may be made to other international and regional instruments. David Wright Advisor Separated Children in Europe Programme International Save the Children Alliance 24 November 1998 Appendix 2 - International refugee and human right instruments The following is the list of all the international and regional instruments that we believe should be considered by the Commission in developing the policy for the European Union in this important area. In the view of Save the Children the following articles are relevant to the situation of refugee children in Europe, and therefore to the work of the Commission: Article 2 - Non-discrimination Article 3 - Best interests of the child Article 6 - Right to Life Survival and Development Article 7 - Name and nationality Article 9 - Separation from parents Article 10 - Family reunification Article 11 - Illicit transfer and non-return Article 12 - The childs opinion Article 20 - Protection of children without families Article 21 - Adoption Article 22 - Refugee children Article 24 - Health and health services Article 26 - Social security Article 28 - Education Articles 34/5 - (Same point as with Article 11) Article 37 - Right to be protected from detention Article 38 - Armed conflict Article 39 - Right to recovery and re-integration On Refugees 1951 UN Convention relating to the status of refugees. 1967 Protocol relating to the status of refugees UNHCR: The Handbook on Procedures and Criteria for Determining Refugee Status (Handbook) Refugee Children: Guidelines on Care and Protection, 1994 Working with Unaccompanied Children: A Community-based Approach, 1996. Guidelines on Policies and Procedures in dealing with Unaccompanied Children Seeking Asylum, 1997 Excomm Resolutions: No. 47, 1987 Refugee Children and No. 59, 1989 also called Refugee Children General International Human Rights Instruments Universal Declaration of Human Rights, 1948. International Covenant on Civil and Political Rights, 1966 ( and Optional Protocol) International Covenant on Economic, Social and Cultural Rights, 1966 International Convention against Torture, 1984 International Convention on the Elimination of all Forms of Racial Discrimination (1965) Convention Relating to the Status of Stateless Persons, 1954 * Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of International Armed Conflicts (Protocol 1), 8 June 1977, Arts. 77 and 78. * Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of Non-International Armed Conflicts (Protocol 11), 8 June 1977, Art. 4. Children - International and Regional Instruments UN Convention on the Rights of the Child, 1989 UN Rules for the Protection of Juveniles Deprived of Their Liberty, 1990 Hague Conference on Private International Law: Convention for the Protection of Minors, 1961 Convention on the Civil Aspects of International Child Abduction, 1980 Convention on Protection of Children and Co-operation in Respect of Inter-country Adoption, 1993 and the associated Recommendation on the Application of the Convention to Refugee Children Convention on Jurisdiction, Applicable Law, Enforcement and Co-operation in respect of Parental Responsibility and Measures for the Protection of Children, 1996 (not in force yet) European Union Joint Action to Combat Trafficking in Human Beings and Sexual Exploitation of Children, Feb. 1997 (97/1 54/JHA) Resolution on unaccompanied minors who are nationals of third countries, June 1997 (97/C 221/03) Europe European Convention for the Protection of Human Rights and Fundamental Freedoms (and Protocols), 1950. The Convention Determining the State Responsible for Examining Applications for Asylum Lodged in One of the Member States of the European Community (Dublin Convention), 1990. Schengen Convention, 1990 European Union: Joint Position on the harmonised application of the definition of the term refugee in Article 1 of the 1951 Geneva Convention relating to the status of refugees, Council of the EU, March 1996 Resolution on Minimum Guarantees for Asylum Procedures, June 1995 Resolution on the harmonisation of national polices on family reunification, I June 1993 Resolution on manifestly unfounded applications for asylum, 1992 Resolution on a harmonised approach to questions concerning host third countries, 1992 Conclusions on countries in which there is generally no serious risk of persecution, 1992 *Council of Europe Recommendations 564 (1969) and 984 (1984) European Social Charter, 1961 Appendix 3 Definition of Separated Children The definition used by this programme is as follows: Separated children and young people are children under 18 years of age who are outside their country of origin and separated from both parents, or their legal/customary primary caregiver. Some children are totally alone while others, who are also the concern of the Separated Children in Europe project, may be living with extended family members. All such children are separated children and entitled to international protection under a broad range of international and regional instruments. Separated children may be seeking asylum because of fear of persecution or due to armed conflict or disturbances in their own country, or they may be the victims of trafficking for sexual or other exploitation, or they may have travelled to Europe to escape conditions of serious deprivation. The following international and European instruments are relevant to this definition: UN Convention on the Rights of the Child Articles. 1 & 22; The Hague Convention for the Protection of Children, 1996, Art.6 ; UNHCR Guidelines, para.3.1; European Council on Refugees and Exiles paras. 8 & 11; EU Resolution on Unaccompanied Minors., Art. 1(1)) However, the experience of this programme has also shown that in the European context the term separated children does not easily translate into some European languages and we therefore see the inevitability that the term unaccompanied children will be preferred. Even so when policies are being formulated, we would encourage that recognition be given to the significance of a childs separation from her/his parents even where they are temporarily in the care of other family members or family friends. PAGE  PAGE 11 PQ|}~4BCTV} $&'((((D)w*x*8O8AAxCCHjIwIxI%M8M9M OOOPRPPP)QQVW&W1W,Z-ZfZhZ]^9`{`abccŵūūūͫūūCJ6>*CJOJQJ>*CJOJQJ5CJOJQJ6CJOJQJ56CJOJQJ0JCJOJQJjCJOJQJUjCJOJQJU CJOJQJBHIz{|}5I$$$HIz{|}5I- . Z [ 4BCUVWX}~xyLxy $$$$&&&(((())C)D)w*x*C-D-.11b3c3_4  _I- . Z [ 4BCUVW$$WX}~xyLxy $$$$&&&(((())$ & F $)C)D)w*x*C-D-.11b3c3_44}6D78888N8O8;;y;z;A & F & F & F & F & F$_44}6D78888N8O8;;y;z;AAwCxCCCHHiIjIwIxIKK$M%M8M9M O OOOPPPPRPSP(Q)QQQV%W&W2W3W,Z-ZgZhZ]^^9`K`L`z`{`bbbbbbbbbbbFcccccccccddffHh         WAAwCxCCCHHiIjIwIxIKK$M%M8M9M O OOOPPPPRP & F$ & F$ & F & F$RPSP(Q)QQQV%W&W2W3W,Z-ZgZhZ]^^9`K`L`z`{`bbbbbbb$bbbbbFcccccccccddffHhIhii j jk kkkl$$cc kkkkkkk]llloqJrQrgr ttUt u!uqxrxsx~xxxzz}}l~~hocxyDEFLMNPQWXZ[\_`0JmH0J j0JU>*CJOJQJ5CJOJQJ56CJOJQJ CJOJQJ6CJOJQJ=HhIhii j jk kkkllllmmnnoo(q)qqqhrirsssssssssssss t t tttttttTtUt u!uuuu v?v`vvvvv*wAw`wwwww!x=xqxrxsxxxxxxxDy~yy'zzzzzz?{{{ |I|}}}}}"~k~dllllmmnnoo(q)qqqhrirsssssssssssss t t t tttttttTtUt u!uuuu v?v`vvvvv*wAw`wwww$`$ww!x=xqxrxsxxxxxxxDy~yy'zzzzzz?{{{ |I|}}$`}}}}"~k~l~~~ghpqفvRk~l~~~ghpqفvRB`abcȅɅ;<xډEFDEPXZ\]^_` 8B`abcȅɅ;<xډEFDENOP&`#$$P\]^_`$&`#$. A!"#$%DyK savechildbru@skynet.beyK <mailto:savechildbru@skynet.be [(@(NormalCJmH 8@8 Heading 1$@& 5OJQJ8@8 Heading 2$@& >*OJQJ<A@<Default Paragraph Font&>@&Title$5.B@. Body Text$66P@6 Body Text 2 6OJQJ, @",Footer  !&)@1& Page Number(U@A( Hyperlink>*B*` c`JTIW)ARPbl tw}P`KMNOQRSVWXY[\_4Hhk~`LPUZP}`X !!t8@0(  B S  ?~  **00k@m@]GdG*S1S7S>S______'v-v~~ckE^a'+$nx n|Gms##6&A&D)* ,,5/A/^/`/_0b00|24444;5G588"9)999v;;t?v?<@FCEE=ENE:GAGHHHH_IwIL LLLMMOOQRVV^^*_._``oaabGdee6ffggdirioop.p&w+wxxxyhyuyv||c<nڅ79E^aSCFUK>C:\My Documents\Asylum & Refugee Children\EUfinaldraft25.6.docSCFUK>C:\My Documents\Asylum & Refugee Children\EUfinaldraft25.6.docSCFUK>C:\My Documents\Asylum & Refugee Children\EUfinaldraft25.6.docSCFUK9C:\My Documents\Asylum & Refugee Children\finalasylum.docSCFUK9C:\My Documents\Asylum & Refugee Children\finalasylum.docSCFUK4C:\Windows\Temp\AutoRecovery save of finalasylum.asdSCFUK9C:\My Documents\Asylum & Refugee Children\finalasylum.docSCFUK9C:\My Documents\Asylum & Refugee Children\finalasylum.docISCAE\\Be_brus_pc10668\Documents\Asylum & Refugee Children\finalasylum.docsian3C:\Sian's folders\internet\Brussels\finalasylum.docB u1:Œ\%  L(:ŒLZ:Œ!Gd ]:ŒoI k:ŒL2" Qa# B $:Œzn& XA9 _: S*< s#= wVI =BP -jP :l Bn o  np~ q f{:Œ+9|  hhOJQJo( hhOJQJo(hh. hhOJQJo( hhOJQJo(hho(. hhOJQJo(hh. hhOJQJo(hh. hhOJQJo( hhOJQJo( hhOJQJo( hhOJQJo( hhOJQJo( hhOJQJo( hhOJQJo( hhOJQJo(hh. hhOJQJo(hh.hho(.hho(.hho(- hhOJQJo( hhOJQJo( hhOJQJo(L2"k:l!Gd np\% ou1]oIf{B $L(BnLZ+9| qwVI=BPBXA9Qa#zn&S*<s#=_:-jP@cccc`@GTimes New Roman5Symbol3& Arial"qh+7&s[f:7f\p9!20dDRAFT FRAMEWORK Mr WrightsianOh+'0t  $ 0 < HT\dlDRAFT FRAMEWORKRAF Mr WrightEWr WNormalhsianlh8anMicrosoft Word 8.0@@BoȾ@ƾ@vm\p՜.+,D՜.+,\ hp  "Charles.Wright Associates Limitedk9 DRAFT FRAMEWORK Title0(RZ _PID_GUID _PID_HLINKSAN{22CDB483-0862-11D3-9F47-444553540000}At(mailto:savechildbru@skynet.be  !"#$%&'()*+,-./0123456789:;<=>?@ABCDEFGHIJKLMNOPQRSTUVWXYZ[\]_`abcdeghijklmnopqrsuvwxyz{}~Root Entry Fm'Y]pmData ^1TablefWordDocumentSummaryInformation(tDocumentSummaryInformation8|CompObjjObjectPoolpmpm  FMicrosoft Word Document MSWordDocWord.Document.89q