COMMITTEE ON ECONOMIC, SOCIAL AND CULTURAL RIGHTS HOLDS DAY OF GENERAL DISCUSSION ON RIGHT TO SOCIAL SECURITY

The Committee on Economic, Social and Cultural Rights today held a day of general discussion on the right to social security, article 9 of the International Covenant on Economic, Social and Cultural Rights, with the aim of formulating a General Comment on that article of the Covenant.

Alessio Bruni, representing the High Commissioner for Human Rights, said the right to social security represented an important legal guarantee aimed at ensuring the right of everyone to live a life in human dignity in situations of social distress such as old age, disability, unemployment, employment injury, illness, childbirth, death, or other unforeseen circumstances. The implementation of that right was also an essential pre-condition for the effective realisation of other related human rights, such as the right to an adequate standard of living, the right to health, the protection of mothers and children, and other rights enshrined in the Covenant and other human rights instruments. Thus, the recognition of social security as a human right represented an essential bridge between needs-based charity to rights-based social justice.

Among the issues raised was the particular situation of developing and poorer countries, and their difficulties in developing or, indeed, adopting a minimal package of social security. The fact that over 50 per cent of the world’s population was not in a situation to access even a minimum standard of social security was raised by many speakers. The over-riding issue was how to extend coverage of social security world-wide, one speaker said.

Another point raised by many speakers was the situation of workers in the informal economy, namely temporary and illegal workers, and the situation of women in this regard, as they formed a large proportion of these workers. More and more, worldwide, women were becoming the backbone of the informal economy, and this should be borne in mind, as existing literature referred to atypical workers, but these were the ones who were rapidly becoming the more typical type, and they should be included in deliberations and discussions, a speaker said.

That social security systems covered less than they had in the past, a trend over the last ten years, was also of concern to many speakers, who raised the issue of retrogression of coverage, and the Committee should consider this and address it further, as this would contribute towards an improvement, and there was a gap with regards to respecting the basic content of the right. There was a risk of watering down what had already been achieved on a global basis, a speaker said.

Addressing the Committee were representatives of the International Labour Organization, the International Social Security Association, the European Committee of Social Rights, the Université de Québec à Montréal, the Centre for Housing Rights and Evictions, UNHCR, FIAN International, the German Institute of Human Rights, the Tata Institute of Social Sciences, Global Alliance for Improved Nutrition, International Organization of Employers, the International Confederation of Trade Unions, and the International Commission of Jurists.

The Committee will next meet in public at 10 a.m. on Friday, 19 May, to conclude its session.

Statements

ALESSIO BRUNI, Team Leader, Treaty Implementation and Follow-up Team I at the Office of the High Commissioner for Human Rights, speaking on behalf of the High Commissioner for Human Rights, said these thematic debates had contributed to fostering a deeper understanding of the contents and implications of specific articles of the International Covenant on Economic, Social and Cultural Rights. On several occasions, days of general discussion had led to the adoption of general comments, which in turn enabled the Committee to clarify the normative content of the rights set out by the Covenant, assist States parties in implementing their obligations under the Covenant, and had enabled other actors to monitor the realisation of those rights in practice. Today’s general discussion offered a unique opportunity for human rights experts, labour and social security specialists, researchers, policy makers and Government representatives to exchange ideas, experiences and perspectives on social security rights and policies. It also provided an opportunity to further reinforce the links between the work of human rights treaty bodies, the Office of the High Commissioner, United Nations specialised agencies and bodies, other inter-governmental organizations, as well as a wide spectrum of employers’ and employees’ organizations, NGOs, and academic institutions.

The right to social security represented an important legal guarantee aimed at ensuring the right of everyone to live a life in human dignity in situations of social distress such as old age, disability, unemployment, employment injury, illness, childbirth, death, or other unforeseen circumstances. The implementation of that right was also an essential pre-condition for the effective realisation of other related human rights, such as the right to an adequate standard of living, the right to health, the protection of mothers and children, and other rights enshrined in the Covenant and other human rights instruments. Thus, the recognition of social security as a human right represented an essential bridge between needs-based charity to rights-based social justice. Nevertheless, the scope and content of the right to social security remained unfamiliar even to legal practitioners, and the human rights dimension of the right was sometimes overlooked. The thematic debate would undoubtedly assist States parties and a wide range of non-State actors in the promotion of the right to social security, and would also enable the Committee to better monitor the implementation of this right at the national level.

MARIA VIRGINIA BRAS GOMES, Committee Expert, introducing the draft general comment, said draft general comments allowed States parties to better understand the interpretation of the Covenant, and allowed Committee members to adopt a common understanding and therefore a common approach to human rights. The formulation of the right in the Covenant corresponded to a vision of social security. The concept of adequate social security for all was the current perception. The massive entry of women into the labour market, new forms of employment and underemployment, globalization with all its consequences and the existence of social security nets and the difficult issues for social security posed by irregular workers were some of the problems posed for social security globally across the planet. It was nevertheless true that about 50 per cent of the world’s most disadvantaged lived without any social security.

First Discussion

GERMAN LOPEZ MORALES, International Labour Office, said the ILO highly appreciated the draft general comment 20. The States parties should adopt the necessary measures to implement fully the right to social security. The type of system used to provide this could not be defined narrowly. To enable States parties to implement the right to social security in light of this interpretation, the draft general comment should clearly define the required level of social security protection. Recourse to international legal instruments could prove useful in this regard, and the level of protection that a State should have to provide either immediately or progressively made clear. For the ILO, there was a basic minimum level of protection which a State had to provide immediately in order to live up to its international obligations, and this level was not negotiable, and should not be questioned from an economic perspective. The ILO’s practical experience showed that there were particular social security priorities. In determining the right to social security, it was also helpful to examine the approach and concepts of other organizations, for example like it was expressed in the European Social Charter. It was of utmost importance that the right to social security was defined by quantitative, qualitative standards, which could be properly monitored. The draft general comment should therefore clearly define terms, and provide clear guidance as to what the right consisted of, and how it could be implemented.

YANNICK D’HAENE, International Social Security Association, said the Association fully supported the document under discussion. The right to social security was of central importance, and crucial for social stability and peace. Social security, one of the major innovations of the twentieth century, was in constant expansion. Over the last ten years, however, the coverage had shrunk for the first time since social security systems were established. Only about 20 per cent of the world’s population had appropriate and adequate social protection, according to ILO figures. Several million people ended up below the poverty line each year due to high health costs. One of the major reasons for the drop in those covered was the increase in the numbers of those who were working in the informal economy. Up until now, systems of social security were based on concepts of solidarity, however, gradually, increasing criticism had been levelled against these principles, because of the alleged inefficiency of the financial transfer mechanisms, among other reasons. The battle was not won, and today there were forces that were bringing into question the very foundations of social security, which was one of the bases of society over the last 200 years. Formal rights were necessary, but no legal system could resist economic constraints or ideological perspectives. What was required was to convince people that having a strong social security system was the best type of investment, as it increased social cohesion, and this was a positive thing. Strong attention should be given by national authorities to true equality of treatment.

Discussion

During the discussion, an Expert wondered whether any country actually met the requirement of having an effective social security system, and how realistic it was to expect developing countries to put in place an effective system that would cover the minimal needs. Even poorer countries, he said, could still have a minimal level, but it was not realistic to expect them to do so immediately. Another Expert said that some countries had realised that social security was vital, and this had led to democraticisation of the country. The social security idea was put forward in the Universal Declaration of Human Rights, as a principle that all had the right to enjoy, and the right appeared to be constantly minimised and curtailed by interpretations made by countries trying to ensure that their system was sustainable. Another Expert noted that many countries that had provided a certain level of protection were transferring some of these responsibilities to the private sector, and the draft general comment should cover this.

Social security was a problem which was of an internal nature in society, another Expert said. The right existed in many countries, but was always evolving. It was not a problem of recognising the right at the international level, but how to ensure social coverage in all countries at the domestic level. The question was how to ensure that the right was fully exercised, in particular in developing countries, but the fundamental issue was at the domestic level, he said. Another Expert noted that there was a large number of people on the planet living under conditions of military conflict and natural disasters, and social security schemes did not work in these areas, and the draft general comment could perhaps pay attention to this issue, he suggested. Another Expert said that the starting point of the draft general comment should be that half of the world’s population had no access to social security, and that the draft was written from the point of view of those who did have full access to social security. Much more attention should be paid to international cooperation, and to the situation of economically-weak States.

A representative of the ILO said the over-riding issue was how to extend coverage of social security world-wide. The International Labour Conference had mandated the ILO to run a global campaign to extend coverage, and some steps had been made in this direction. It was clear that whether a minimum package of benefits was affordable to poorer countries had to be discussed. The question was how these could afford fiscal space to achieve this minimum package. There needed to be a movement towards investigating how informal networks could be introduced and sustained, she said. An Expert noted that the draft general comment included the progressive realisation of minimal standards of social security.

Second Discussion

JEAN-MICHEL BELORGEY, European Committee of Social Rights, said certain questions came up whatever part of the world was examined. The European Social Charter had certain elements within it, including social assistance, and contained articles dealing with various aspects of social security, health, elderly persons, maternity protection and others. Implementing and ensuring the right to social protection meant providing services in terms of all these. In the past, there had been a clear division between social security and assistance. Some contemporary systems combined these today. A reasonable number of risks had to be covered, without discrimination in terms of age, sex, origin and race. As far as possible, it should be ensured that benefits should not be provided at the expense of the services which should also be provided. Other outstanding issues were often psychological. There was discrimination, and not just among women who made up most part-time workers, but also for those workers in the weakest position. A unique solution could not be found, but basically social security was a question of choice, which should be explicit, and not forced on people in conditions which led to selective approaches or abuses from which those in the weakest position suffered the most.

LUCIE LAMARCHE, Université du Québec à Montréal, said it was important to bear in mind that article 9 of the Covenant provided for the fact that any individual had the right to social security, including social insurance. Article 9 should be linked to article 11 of the Covenant, as there was an irrefutable link between them. When it came to social security, language mattered. More and more, worldwide, women were becoming the backbone of the informal economy, and this should be borne in mind, as existing literature referred to atypical workers, but these were the ones who were rapidly becoming the more typical type, and they should be included in deliberations and discussions. There was a need to examine the retrograde situation further, as this would contribute towards an improvement, and there was a gap with regards to respecting the basic content of the right. The language of gradual implementation had to be used without setting priorities. The document clearly set up approaches. It was important to stick to the positive proposal contained in paragraph 3 of the draft general comment, and to bear in mind the importance of the result, and not the debate on the nature of the system. The trend to replace specific legislation which met real problems and risks by framework laws which had noble principles, goals and objectives, but had the disadvantages of being very vague had to be avoided at all costs.

MALCOLM LANGFORD, Centre for Housing Rights and Evictions, said the right to social security had the worst level of realisation of all rights in the Covenant. Discrimination had to be taken into consideration in this context, among other things, as even in advanced countries there were particular human rights issues to be faced. The lack of an international movement focussing on this right was also of concern. That the Committee recognised the right to a social security system was positive, as this was a requirement that any social security model had to meet certain criteria, and the State had an obligation to focus on the right to social security of women and marginalized and disadvantaged groups, including those of the informal sector. Social security was a collective right, and the involvement of the private sector therefore required close supervision. The issue of physical accessibility needed to be reviewed within the draft general comment in order to be clarified. The issue of eligibility and suspension criteria should also be examined further. Social security systems would also have to rise to the challenge of reducing the gender gap between wages. The Committee could also perhaps to be bolder on the situation of illegal migrants, and to what extent they could access social security. Retrogression was also a particular concern which the Committee should examine.

Discussion

The issue of illegal immigrants was raised by an Expert, who said he was troubled by the lack of an attempt to establish a legal differential treatment within the draft general comment, referring to the situation of countries which contained many refugees, and he said that social security went beyond the UN Refugee Convention. In this particular area, it was reasonable to differentiate between nationals and non-nationals, he said, and there was a need to take care when extending the right of social security to all across the board, as this would place a greater weight on countries and make them more reluctant to implement the right. Another Expert raised the issue with regards to asylum seekers. What could be understood by “the right to social security without discrimination” was raised by a third Expert, who said there had to be form of discrimination in the name of social solidarity at least.

An Expert said the introduction of the private sector in matters of social security should be further discussed privately before its inclusion in the draft general comment. Technological concepts could be included in the text, but there needed to be clarity as to their meaning before this took place.

A representative of the High Commissioner for Refugees said UNHCR welcomed the emphasis given to non-discrimination in securing access to social security, as well as the clear call upon States to give special attention to those individuals and groups who had traditionally faced difficulties in exercising their right to social security, including refugees, asylum-seekers and stateless persons as well as returnees. A representative of FIAN International said the informal sector was included in the text on the section on marginalized workers and that on co-obligations, there were very few explanations of how to cover these people, and there was a need for further clarification of what was expected.

A representative of the German Institute of Human Rights said the purpose of social security as a human rights claim was not on social risk provisions as such, but rather on addressing all forms of discrimination and exclusion from existing societal institutions of risk provisions, and some clarification in the draft general comment would be useful to sharpen the specific profile of the human approach in the conceptualisation of social security. A representative of Tata Institute of Social Sciences, Mumbai, said that research had resulted in a disconnect between the political and social benefits of social security, with an underplaying of the benefits, and the general comment should strongly emphasise these. It was very important to understand that the continued low-tax/GDP ratios in developing countries were largely responsible for the argument that there was not enough money to implement social security for all, he said. A representative of Global Alliance for Improved Nutrition said the general comment could play a role in empowering the social sector in providing extended forms of social security.

Discussion 3

ANGELIKA NUSSBURGER, International Labour Office, said the majority of countries of the world were bound by the Covenant, and the draft general comment was an ideal basis for forming a consistent international instrument for the understanding of social security. There were different concepts of social security, and one of these should be selected. There was a danger of watering down what had already been achieved. Social security was understood as the reverse side of the right to work, and this was a rather narrow concept, as it did not include the right to health and to medication, for example. The different concepts had to be determined, and the different parts of the draft general comment contained references to the different types. Social security should not be viewed only as a poverty alleviation programme. Jurisprudence on private and civil rights made it clear that the right to social security was viewed as a right to property, and should be protected as such, and migrant workers had to be allowed to benefit from what they had contributed to. The ILO had developed a comprehensive and very detailed system in Convention 102, with very clear State obligations, but this was very technical and difficult to understand.

MICHEL BARDE, International Organization of Employers, said the world was currently changing, and in a globalized world, social security was becoming increasingly important, as it had to encompass new risks that did not seem to be specific only to workers, such as family payments, and therefore had to fit into the framework of broader national priorities, and could not be considered in isolation. The facts that any social security model had to conform to the socio-economic realities of a country had to be taken into account: there was no single model which would suit all. There had to be a balance between the resources needed for social security and the need to maintain employment, competitiveness, and economic growth. Employers should not be called upon to bear its costs alone. Further research was required on the impact of social security on employment and job creation. A balance had to be found to ensure that social security in and of itself did not become a barrier to employment. The problem of the long-term viability of retirement systems also had to be taken into account. An economic recession led to higher unemployment, and a drop in social security contributions: social security only worked when the economy was robust. Without an active employment policy incorporating social aspects, there could be no social security.

ANNA BIONDI, International Confederation of Trade Unions, said income security had to be provided in order to protect against accidents, as well as for preventing or alleviating poverty. Social security enhanced productivity, and the economic advantage of it needed to be examined further. Social security was a crucial component of decent work, however, and should not be examined simply as a productive factor. Social security and social protection also helped development on many levels, including health care, which had been demonstrated to have a positive effect on GDP growth. Social protection helped workers to deal with difficult phases of life. What was needed was better data, and more research into best practices and the search for fairer globalization. The need to combat feminised poverty through social security policies needed to be recognised, as women were poorly represented in the labour market, and their inclusion in the formal economy needed to be discussed further in order to ensure that a plan of action was formulated. Social security as part of social protection and part of decent work was at the core centre of the Millennium Development Goals and all its components. It was now time to promote a comprehensive approach to policy formulation, and social protection had to be a pillar for this process.

Discussion

A representative of the Centre on Housing Rights and Evictions said the draft general comment tried to combine elements such as human dignity with the ILO Convention 102, and wondered how the Committee would combine the human rights approach with the need to realise social security. To what extent did poverty alleviation schemes constitute a form of social security, he wondered. An Expert said Ms. Nussburger’s statement had been very interesting, but the draft general comment had opted for a comprehensive approach, as if not, then the right to social security would be entirely left to the systems as they had developed within the ILO, and there would be very little possibility of extending it. If social security was treated in a more limited field, then it would not include the reality in most countries. Another speaker said it was important for the ILO to defend the rights of those who were better off, and there should be a dual system, in which it was possible to defend the rights of those living outside the formal sector, whilst protecting those who were in the regular system.

Responding, Ms. Nussburger said the problem with social security was that the basic idea was a form of savings which was accumulated through solidarity. The basic problem was that it was difficult to treat individuals in exactly the same way, whether they had saved or not. The approach under the European Convention on Human Rights to treat social security rights as property rights was one way of dealing with this. Social assistance had to be covered in some way in the Covenant, either under article 9 or article 11. The different elements of the ILO approach and the human rights approach should be compared.

An Expert explained why the Committee had decided that social security should be addressed under article 9, saying that it was part of a wish to cover people who because they were work-related had protection, as well as those who were not covered, such as vendors on the street, who were not considered to be important enough to be covered. There was no concern that the Committee would come into conflict with ILO Convention 102, as it often recommended that States parties ratify these conventions. The Committee tried to link the right to social security to the right to an adequate standard of living, the right to work, to adequate housing and others, not from the point of view of collective rights, but as rights that were interdependent.

A representative of the ILO said the ILO was not excluding in its concerns the situation of those in poverty, and was coming to a complementary approach. There were large parts of the world where ratification of Convention 102 was not a possibility in the near future, but a certain contribution was possible. It was not a useful discussion to fragmentize, as the issues before all were so important, that there had to be a coming together. Another speaker said the expression “every person” in article 9 showed that it was the only possible solution, as it brought together all the different approaches such as that of the ILO and that of the European Convention. An Expert said social security today had the form of funds in which those who earned placed assets, but if the concept of solidarity were to be eliminated entirely, then there would just be a private system which did not include those who for some reason could not contribute, and this would leave a lot of people completely unprotected. The State had to provide in some way for these, and if the basic principle of solidarity was eliminated, she wondered how this would be done.

Responding, Mr. Barde said the human rights discussions were somewhat intellectual and rather remote from the reality on the ground. Everybody should have the possibility of putting their shoulder to the wheel, and everybody in the population should have in some way the right, starting from the lowest possible level, which should slowly be brought up, to contribute. What was essential was that everybody ought to be integrated somewhere into the system, bearing in mind the economic potential and resources of the country concerned. Another speaker said in terms of the draft general comment, one of the most important issues was the role of private pension funds on the equity markets, as the former were one of the largest stakeholders today, and there was concern for what was at stake for the private pension funds in the very volatile equity markets, and this complication needed to be dealt with.

Fourth Discussion

Christian Courtis, International Commission of Jurists, said the wording of the draft general comment was very shy. The approach in article 3 was endorsed, and another point there was that if the Covenant just stuck to ILO Convention 102, then it was stuck in the 1950s approach of work for all, and today’s picture was not similar to that. There had been changing values of the right to social security, and this was the right of every person, not just a right for workers or those in the formal sector. On adequacy, this could include a principle which had something to do with the proportion between the salary and the pension, as this had a replacement character. On accessibility, there were some doubts with regards to the reference to physical accessibility, as this was not clear as to its scope. Traditional social security schemes often drew on the concept that workers were men, and that women had an ancillary position, mainly reproductive, and were framed from this point of view; of course, this had changed significantly. Another issue was persons with disabilities, as in the past they were considered not to be able to work at all, and this was inconsistent today, as systems empowered persons with disabilities.

PAULINE BARRETT-REID, Social Security Expert on Africa, International Labour Organization, said one of the crucial questions was how to extend social security coverage in Africa, in particular with regards to access to pensions and to health care. There was a problem with regards to overall limited fiscal space, the overall level of GDP spent on social security, the impact of HIV/AIDS, the lack of confidence in social institutions, due to poor governance. It was a dire picture. Lack of coverage was concentrated in the informal sector and in rural areas, where insecurity was at its highest. The usefulness of applying a set of principles should be considered: the question of universality and sustainability; social solidarity between all types of groups; strong and well-functioning social dialogue; the application of the rule of law at the national and international level, with an emphasis on international legal instruments; the role of the State in providing good governance was a fundamental; and all this should also be put in a context of decent work. This universal package would be a minimal package, with universal access to a minimal level of social care. The issues of debt relief, of overseas direct aid and of direct budget support needed to be addressed, as did the issue of global funds. Social solidarity was the means by which societies achieved social cohesion, without which there was loss and the alienation of the individual from society, and included issues of monetary redistribution. There were a number of issues that needed to be examined both from a national and international perspective. At the end of the day, it was only the State that could ensure that the necessary factors were in place, such as good governance, good administration, no framework, and decent salaries, whilst integrated into the employment and rights perspective, in order to ensure that there was effective social security.

VIJAY K. NAGARAJ, Tata Institute of Social Sciences, Mumbai, said the draft general comment was a welcome step, and a timely reiteration of the need to protect the dignity and human rights of the marginalized and the vulnerable and ensure growth and development that was inclusive. Developing countries presented several distinctive features and characteristics that had to be kept in mind whilst discussing social security. The idea of social security that the draft general comment appeared to rely on was one which was focused on dealing with the negative effects of development. For social security to be meaningful in the developing country context, it had to address not only negative outcomes of growth but also promote equality of opportunity, and address both the empowerment and the insurance imperatives. Social security was most effective in developing countries when it was fully integrated with larger anti-poverty programmes and initiatives even while being distinguished from general development policy. The draft general comment needed to build on a more critical understanding of the pattern of risk and vulnerability of the millions of poor in the developing world, and to account for the reality of the world of risks and vulnerability of the poor. It should ground the principles of both equity and efficiency in design and implementation of social security programmes. Social security was not just a means to make growth more efficient and equitable; like all human rights it should be seen as both a means and an end.


Discussion

An Expert said that it seemed what was required in order to have an effective social security system was in effect democracy, and this could be included in the draft general comment. Ms. Biondi said with regards to the informal economy there was a need to be careful and not go to the lowest common denominator, as there was a slight tendency to create a cleavage between the workers who had, and those that had nothing. There was a new addition today, where social protection could be used to move towards the idea that the scheme of social security could be established, and it would be a factor for inducing development. Mr. Langford said what needed to be addressed was which risks the Government ought to be focussing on in advance with regards to the informal sector. Ms. Lamarche said there was the perception that the classical informal worker was not a waged worker, and this was incorrect, as was the idea that the informal sector could be linked to the black market. The concept of discrimination as far as economic resources were gained from the informal sector had limits, she said. Ms. Nussburger said the text should be broader and clearer to include those who had nothing whilst protecting those who had something, and suggested a change to the first paragraph of the draft general comment. Mr. Nagaraj said where there was hunger there was illness and no productivity, and the right of people to food, particularly the rural and urban poor, should be protected in the text. Democracy was extremely important in regards to the right to social security, as without those basic standards, social security would not work. Social security should also be integrated as a large part of poverty elimination measures, he said.



Comments by Rapporteurs

MARIA VIRGINA BRAS GOMES, Committee Expert and Rapporteur, rounding up the day’s discussion, said there was only so much a general comment could do, and people should bear this in mind. There were a few things which had struck her, one of which was the last idea on democracy, which was required for social security, pointing out that in some Western democracies, the State was pulling out, and that although democracy was required at the outset, it was not enough to preserve the situation. The issue of empowerment was important, and required further attention, as did the understanding of risks and vulnerabilities. In relation to children, the draft general comment had included the term “families” with a stipulation to concentrate the benefit on the child, and this was to avoid repeating the work of other Committees. In many countries, the State had been pulling back from its social responsibilities, opting for capitalised systems, and the issue was what would happen when that money went astray. Broader frameworks for protection existed after ILO Convention 102.


EIBE RIEDEL, Committee Expert and Rapporteur, said many elements which the drafting committee would have to take up had been raised today, some of which were the informal sector, and how this should be dealt with in the draft general comment; how the core minimum should be reached in line with ILO Conventions; and the clear need to define the material scope of application and the reach of the general comment. Some good points were made with regards to military conflicts and emergency situations; that in some African countries the question of affordability was not the key issue. It was clear that on the informal sector, it was hidden away under migrants in the text, and a clearer definition that was not exclusive and limiting was required here. Not everything that was desirable and that were policy choices were in the remit of the Committee, however. The Committee could not legislate, it was interpreting an international standard in the light of international law and what was binding on States parties. Retrogressive measures should be addressed and a balance struck. Illegal migrants and emergency assistance on health care were very touchy issues on which States felt very different. A vast majority of speakers would opt for the comprehensive approach that the draft was taking, but the opinion that the draft required more clarity as to what was its starting point was also important and would be taken into account.


For use of the information media; not an official record

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