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PROTECTION NOT ENFORCEMENT - The role of the National Referral Mechanism for Victims of Trafficking in the Asylum Process Zofia Duszynska, Asylum Aid 21 July 2009 The United Kingdom ratified the Council of Europe Convention on Action against Human Trafficking on 17 December 2008 and the Convention came into force in the UK on 1 April 2009. The purposes of the Convention as described in article 1 are: “a to prevent and combat trafficking in human beings, while guaranteeing gender equality; b to protect the human rights of the victims of trafficking, design a comprehensive framework for the protection and assistance of victims and witnesses, while guaranteeing gender equality, as well as to ensure effective investigation and prosecution; c to promote international cooperation on action against trafficking in human beings. “ Clearly the drafters and signatories to the Convention envisaged a multi-agency cooperative approach to combating trafficking with an extremely high emphasis on victim protection and assistance, including provisions on compensating victims of trafficking. UKBA states on its website that the UK was largely compliant with the Convention prior to ratification and only made a limited number of legislative, policy and procedural changes to enhance arrangements, notably around victim identification and protection, some of which go beyond the Convention’s requirements. However the very nature of the trafficking process means that many victims of trafficking to the UK will be in the country illegally, either as overstayers or illegal entrants and therein lies the problem. This paper will look at experience of the operation of the Convention so far and examine the conflicts inherent in UKBA’s dual role of enforcing immigration control and identifying victims of trafficking with protection needs. Key obligations of the Convention The principal obligations in terms of victim protection are 1: 1. Their identification, and once identified a commitment that a victim should not be removed from the territory until the identification is complete (article 10) 2. Assistance for victims (article 12) 3. A reflection and recovery period during the two stages of the identification process (article 13) 4. Residence permits in specified circumstances for identified victims of trafficking (article 14) 5. Legal assistance and compensation for victims (article 15) National Referral Mechanism Individuals must consent to the referral of their trafficking accusation under the National Referral Mechanism. Identification of victims In the UK the identification of victims of trafficking occurs in a two stage process conducted through the National Referral Mechanism for victims of trafficking. A full description of the operation of the National Referral Mechanism (NRM) for victims of trafficking (VoT’s) can be found on UKBA’s website. In essence, the system envisages that VoT’s will be identified or come to the attention of “first responders” who if they think that there are indicators of trafficking in an individual’s case and the individual consents to referral, can refer the individual’s case to the competent authority who will carry out the identification process. The referral is made on the referral form which lists indicators of trafficking to assist the “first responder”. The competent authority is UK Border Agency where there are immigration and asylum issues to be considered and UK Human Trafficking Centre (UKHTC) where this is not a concern, eg for EEA nationals. The competent authority (CA) has 5 days from the receipt of the referral to reach a decision on whether there are reasonable grounds to believe the individual is a potential victim of trafficking (PVoT). UKBA Asylum Process guidance states that “The „reasonable grounds‟ test has a low threshold and is lower than the threshold required for prima facie evidence (which is legally sufficient evidence, that if contested, would establish a fact or raise a presumption of a fact). The test that should be applied is whether the statement “I suspect but cannot prove” would be 1 Full text of articles 10-15 appended true and whether a reasonable person would be of the opinion that, having regard to the information in the mind of the decision-maker, there were reasonable grounds to suspect the individual concerned had been trafficked.” The 5 day reasonable grounds decision, if positive will trigger a 45 day reflection and recovery period. During this time, the CA should continue its investigation and complete its inquiries into whether there are conclusive grounds to believe the individual is a victim of trafficking. The purpose of the recovery and reflection period is to enable the VoT to access the support and assistance necessary to escape and recover from the trafficking situation and also to take an informed decision on whether to cooperate with the authorities. The explanatory notes to the Convention 2 show that this reflection and recovery period was specifically designed to protect illegal entrants from being removed from the territory before their case has been fully investigated, before they have had a chance to recover from their situation or consider cooperation with the authorities. The designation of UKBA and UKHTC as the competent authority – that is the only authorities able to make decisions that there are reasonable grounds or conclusive reasons to believe that an individual has been trafficked – creates obvious difficulties and has been the subject of much debate elsewhere. The Explanatory Notes to the Convention itself state: “128. Paragraph 1 places obligations on Parties so as to make it possible to identify victims and, in appropriate cases, issue residence permits in the manner laid down in Article 14 of the Convention. Paragraph 1 addresses the fact that national authorities are often insufficiently aware of the problem of trafficking in human beings. Victims 2 Extract from Explanatory Notes to the Convention “172. Article 13 is intended to apply to victims of trafficking in human beings who are illegally present in a Party’s territory or who are legally resident with a short-term residence permit. …173. Article 13(1) accordingly introduces a recovery and reflection period for illegally present victims during which they are not to be removed from the Party’s territory. The Convention contains a provision requiring Parties to provide in their internal law for this period to last at least 30 days. …. One of the purposes of this period is to allow victims to recover and escape the influence of traffickers. Victims recovery implies, for example, healing of the wounds and recovery from the physical assault which they have suffered. That also implies that they have recovered a minimum of psychological stability. Paragraph 3 of Article 13, allows Parties not to observe this period if grounds of public order prevent it or if it is found that victim status is being claimed improperly. …174. Other purpose of this period is to allow victims to come to a decision “on cooperating with the competent authorities”. By this is meant that victims must decide whether they will cooperate with the law- enforcement authorities in a prosecution of the traffickers. From that standpoint, the period is likely to make the victim a better witness: statements from victims wishing to give evidence to the authorities may well be unreliable if they are still in a state of shock from their ordeal. …” frequently have their passports or identity documents taken away from them or destroyed by the traffickers. In such cases they risk being treated primarily as illegal immigrants, prostitutes or illegal workers and being punished or returned to their countries without being given any help. To avoid that, Article 10(1) requires that Parties provide their competent authorities with persons who are trained and qualified in preventing and combating trafficking in human beings and in identifying and helping victims, including children and that they ensure that those authorities cooperate with one other as well as with relevant support organisations. 129. By “competent authority” is meant the public authorities which may have contact with trafficking victims, such as the police, the labour inspectorate, customs, the immigration authorities and embassies or consulates. It is essential that these have people capable of identifying victims and channelling them towards the organisations and services who can assist them. 130. The Convention does not require that the competent authorities have specialists in human-trafficking matters but it does require that they have trained, qualified people so that victims can be identified. The Convention likewise requires that the authorities collaborate with one another and with organisations that have a support-providing role. The support organisations could be non-governmental organisations (NGOs) tasked with providing aid and support to victims. “ First responders Referrals to the CA can only be made by a first responder, which is limited to the police, local authorities and certain NGO’s such as the Poppy Project. Solicitors and legal representatives cannot make a referral to a CA and an individual cannot self refer, other than by presenting themselves at the Asylum Screening Unit and hoping that they are identified as a victim of trafficking. This effectively limits the routes by which a PVoT can be referred to the NRM. Unless they are able to access the services of the Poppy Project (or other NGO) who can refer their case, they must either identify themselves to the police if an adult, or to social services if a child. The NRM and the asylum process Asylum Process Guidance and the NRM route map indicate that the asylum process and NRM are intended to co-exist and run in parallel. The guidance states that if they have received a positive 5 day RG decision, VoTs can still be interviewed about their asylum claim during their reflection period. The guidance also states that those who are likely to receive a negative RG decision must be interviewed about their trafficking case. In practice, where a PVoT has claimed asylum, asylum interviews are being used to assess the trafficking case, which means firstly that RG decisions are not being made within the 5 day period, secondly that asylum interviews whose purpose is to assess an individual’s prospective risk of persecution and prospective need for international protection are being used to assess the credibility of an individual’s account of past persecution and trafficking, and thirdly that the individual will have no chance to benefit from the reflection and recovery period which would be the result of a positive 5 day decision. Reasonable grounds decision before asylum interview From the inquiries made by the author, it seems that currently, where a PVoT identifies herself to UKBA and claims asylum, the reasonable grounds’ decision will be made and issued to the asylum applicant at the same time as the asylum decision. This is the case whether the asylum applicant is in the detained fast track or in the community. The justification for this seems to be that it is the interviewing caseworkers are the UKBA staff who have been trained in trafficking victim identification rather than front-line staff at the ASU and that UKBA requires detailed information about the applicant’s case which can best be obtained by the interview process. In the author’s view, the identification should not take place concurrently with the asylum decision. This negates the purpose of article 13 of the Convention and risks depriving the applicants of any benefit of the Convention or of the reflection and recovery period which they would receive if they were identified as PVoTs. This is important because of the existence of the detained fast track. Currently, If a PVoT claims asylum and meets UKBA’s suitability criteria for the Detained Fast Track (DFT), then s/he will be referred to the DFT even though a reasonable grounds decision has not yet been made. UKBA policy is that any case may be suitable for DFT if is appears that a quick decision can be made. Although a quick decision is not likely in a case where “it is foreseeable that further enquiries (whether by UKBA or the applicants) are necessary to obtain clarification or corroborative evidence, without which a fair and sustainable decision could not be made, where those enquiries cannot foreseeably be concluded to allow a decision to take place in the normal indicative timescales3,” experience so far suggests that the need to make a reasonable grounds decision has not been found to fall into that category. However you will not be considered suitable for the DFT if you fall into the category of “Those for whom there has been a reasonable grounds decision taken (and maintained [UKBA emphasis]) by a competent authority stating that the applicant is a potential victim of trafficking or where there has been a conclusive decision taken by a competent authority stating that the applicant is a victim of trafficking.” Where the Medical Foundation or Helen Bamber Foundation have stated that they have undertaken to complete an assessment of whether an asylum applicant is a victim of torture, 3 UKBA “Detained fast Track” UKBA has accepted that those people will not be suitable for DFT. In the past, the same consideration was given to the Poppy Project in cases where they had undertaken to assess an asylum applicant for evidence of trafficking. That is no longer the case. The combination of these factors leads to the obvious risks that a PVoT who has claimed asylum will not have been identified as a PVoT when claiming asylum – as those decisions are not taken at the ASU, and will be placed in the DFT because she has not received a positive RG decision and because her trafficking situation will not have been identified at the ASU and therefore not have raised the query about whether her case can be decided quickly. Further detailed enquiries by NGOs and other professionals working in the field will be hampered by difficulties of speed of response and power to intervene and a reasonable grounds decision will be taken while the PVoT is in the DFT without further enquiries having been made. This is without going into the difficulties that victims of trafficking face in disclosing their trafficking experiences – difficulties which are described and therefore recognised in the UKBA Asylum Process Guidance for Victims of Trafficking. Further the purpose of the 45 day reflection period is to enable the PVoT to recover from her experience, reflect on whether she wishes to request international protection or victim assistance and decide together with the investigating authorities whether to assist with police investigations and prosecutions. To complete the asylum decision-making process at the same time as the initial victim identification process deprives the PVoT of the opportunity of the period of reflection to make an informed decision about her choices. Conflation of immigration process and victim identification process Another conflict in the victim identification procedure currently is that the RG decisions are being taken by the same caseworker and at the same time as the asylum decision and there is evidence of conflation of the two processes in the decision-making. For example, caseworkers have issued decisions stating that because an applicant expressed a wish to return to her own country and requested her passport back, she wasn’t trafficked. The definition of trafficking is contained in article 4 of the Convention, and is the same definition adopted by the UN in its Palermo Protocol: For the purposes of this Convention: a "Trafficking in human beings" shall mean the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs; Given that the asylum process examines prospective risk of future persecution and the victim identification process is an examination of past ill-treatment and abuse, it is strongly arguable that the decisions should not be made by the same person at the same time and that there is little benefit to having the decisions made by the same person at the same time. (Asylum applicants are very frequently told during their asylum interviews that the applicant does not need to describe the persecution they have experienced previously and that the interviewer wishes to concentrate on their risks on return). Particularly important in this are the implications for any investigation of the traffickers if it is concluded that the PVoT is a victim of trafficking. It would grossly undermine the purpose of the Convention if potential prosecutions of traffickers were rendered impossible because the credibility of the victim had been damaged by UKBA in the decision-making process. The Asylum Process Guidance stresses this point : “Decision makers need to be aware that any deliberations that are made will be subject to rules of disclosure in any subsequent prosecution for trafficking. Where an individual is being treated by the police as a potential victim and/or witness, decision-makers should ensure lines of communication with the Senior Investigating Officer (police) are kept open. The decision as to whether there is enough evidence to prove that an individual is a victim rests with the CA but officers must be alert to the impact that the decision may have not only on the victim but on a criminal investigation and the criminal justice process.” The high emphasis in the Convention on the combating of trafficking through the prosecution of traffickers should imply an obligation on the CA to refer each allegation of trafficking for preliminary investigation before a reasonable grounds decision is issued to ensure that the prospects of bringing prosecutions are not damaged by decision-making that has been taken on the basis of poor information, little or no investigation and lack of comprehension of the trafficking definition. Challenges to negative reasonable grounds decisions There is no statutory right of appeal against a decision that there are no reasonable grounds to believe that an individual is a victim of trafficking. The only route of challenge is through Judicial Review. However to be effective, the timing of any challenge is crucial. If a victim of trafficking has claimed asylum, the credibility of her account of trafficking will be vital to the success of any asylum claim, and yet the specific findings of a reasonable grounds decision cannot be challenged in the AIT. Although Immigration Judges have the duty to make their own findings of fact in an immigration appeal, it will clearly present additional hurdles for an appellant to overcome to succeed in an asylum appeal where the account of past persecution has been disbelieved but a decision relating to that account has yet to be challenged in the High Court. Further, if an asylum appeal should fail on the basis of the credibility of the trafficking account, any subsequent attempt to challenge a negative reasonable grounds decision runs the risk of being accused of trying to undermine the findings of the AIT and making a collateral challenge. This presents additional difficulties for potential victims of trafficking who are in the detained fast track where the speed of the appeal process will limit the time available to challenge the NRM decision. To protect the victim’s rights, it appears that the NRM decision must be challenged before the asylum appeal. Witness Protection or International Protection If a positive reasonable grounds decision is made, then the CA together with other agencies will continue to investigate the victim’s case and after 45 days (unless extended for further enquiries) a 45 day conclusive decision will be made on whether the PVoT is a victim of trafficking or not. The Asylum Process Guidance indicates that the investigation of the applicants; asylum claim can also occur during this time “if the person is able and willing to participate, taking into account any trauma they may be suffering.” The Asylum Process Guidance also stresses that the test for making a conclusive decision is the “balance of probabilities” “Decision makers should be satisfied that the trafficking conduct occurred if they consider that, on the evidence, the occurrence of the event is more likely to have happened than not. This standard of proof does not require the decision maker to be certain that the event did occur.” The Convention provides for the issue of a 12 month residence permit to victims if: a the competent authority considers that their stay is necessary owing to their personal situation; b the competent authority considers that their stay is necessary for the purpose of their co-operation with the competent authorities in investigation or criminal proceedings. Under the National Referral Mechanism, it is the police twho must apply for a residence permit for the VoT is s/he is cooperating with any investigation or any criminal proceedings. If the victim is not cooperating with an investigation then UKBA is to consider whether there are any compassionate factors meriting a grant of 12 months’ discretionary leave to remain in the UK. A decision that there are no compassionate factors meriting a grant of DL is not appealable. The question of the protection to be given to a victim of trafficking who has claimed asylum has provoked concern. The residence permits issued under the NRM are to be for 12 months exactly which would prevent an applicant from appealing a decision to refuse asylum. However article 40(4) of the Convention states: 4 Nothing in this Convention shall affect the rights, obligations and responsibilities of States and individuals under international law, including international humanitarian law and international human rights law and, in particular, where applicable, the 1951 Convention and the 1967 Protocol relating to the Status of Refugees and the principle of non-refoulement as contained therein.” UKBA has indicated that where a potential VoT has claimed asylum, her asylum claim will be decided first, thereby ensuring that a victim will benefit from full consideration of her need for international protection first before moving on to a consideration of whether temporary residence as witness or discretionary leave is appropriate. However id asylum were to be refused and a residence permit for 12 months issued, there would be no statutory right to appeal the decision and the only challenge would appear to be by judicial review relying on article 40. The NRM has been in operation only since April 2009 and as yet there has not been sufficient experience to see how the relationship between the Trafficking Convention and refugee Convention works in practice. However, anecdotally, it is known that individuals whose cases were dealt with under the pilot programme were informed that decisions on their asylum cases could not be reached until the police investigation was completed. Where those individuals are cooperating with a police prosecution, the police have requested residence permits experience for those individuals and asylum decisions have not been made. It is unclear whether UKBA has the intention of deciding these asylum claims at the end of the 12 month residence permit, in which case any refusal of asylum would attract a right of appeal. The UK’s obligations under the Convention are however clear - that the Trafficking Convention is not intended to have an adverse effect on an individual’s rights under any other aspect of international humanitarian law. Appendix Key articles of the Convention on Action against Human Trafficking Article 10 - Identification of the victims - 1 Each Party shall provide its competent authorities with persons who are trained and qualified in preventing and combating trafficking in human beings, in identifying and helping victims, including children, and shall ensure that the different authorities collaborate with each other as well as with relevant support organisations, so that victims can be identified in a procedure duly taking into account the special situation of women and child victims and, in appropriate cases, issued with residence permits under the conditions provided for in Article 14 of the present Convention. 2 Each Party shall adopt such legislative or other measures as may be necessary to identify victims as appropriate in collaboration with other Parties and relevant support organisations. Each Party shall ensure that, if the competent authorities have reasonable grounds to believe that a person has been victim of trafficking in human beings, that person shall not be removed from its territory until the identification process as victim of an offence provided for in Article 18 of this Convention has been completed by the competent authorities and shall likewise ensure that that person receives the assistance provided for in Article 12, paragraphs 1 and 2. 3. When the age of the victim is uncertain and there are reasons to believe that the victim is a child, he or she shall be presumed to be a child and shall be accorded special protection measures pending verification of his/her age. 4. As soon as an unaccompanied child is identified as a victim, each Party shall: a provide for representation of the child by a legal guardian, organisation or authority which shall act in the best interests of that child; b take the necessary steps to establish his/her identity and nationality; c make every effort to locate his/her family when this is in the best interests of the child. Article 12 – Assistance to victims 1. Each Party shall adopt such legislative or other measures as may be necessary to assist victims in their physical, psychological and social recovery. Such assistance shall include at least: a standards of living capable of ensuring their subsistence, through such measures as: appropriate and secure accommodation, psychological and material assistance; b access to emergency medical treatment; c translation and interpretation services, when appropriate; d counselling and information, in particular as regards their legal rights and the services available to them, in a language that they can understand; e assistance to enable their rights and interests to be presented and considered at appropriate stages of criminal proceedings against offenders; f access to education for children. 2 Each Party shall take due account of the victim’s safety and protection needs. 3 In addition, each Party shall provide necessary medical or other assistance to victims lawfully resident within its territory who do not have adequate resources and need such help. 4 Each Party shall adopt the rules under which victims lawfully resident within its territory shall be authorised to have access to the labour market, to vocational training and education. 5 Each Party shall take measures, where appropriate and under the conditions provided for by its internal law, to co-operate with non-governmental organisations, other relevant organisations or other elements of civil society engaged in assistance to victims. 6 Each Party shall adopt such legislative or other measures as may be necessary to ensure that assistance to a victim is not made conditional on his or her willingness to act as a witness. 7 For the implementation of the provisions set out in this article, each Party shall ensure that services are provided on a consensual and informed basis, taking due account of the special needs of persons in a vulnerable position and the rights of children in terms of accommodation, education and appropriate health care. Article 13 – Recovery and reflection period 1 Each Party shall provide in its internal law a recovery and reflection period of at least 30 days, when there are reasonable grounds to believe that the person concerned is a victim. Such a period shall be sufficient for the person concerned to recover and escape the influence of traffickers and/or to take an informed decision on cooperating with the competent authorities. During this period it shall not be possible to enforce any expulsion order against him or her. This provision is without prejudice to the activities carried out by the competent authorities in all phases of the relevant national proceedings, and in particular when investigating and prosecuting the offences concerned. During this period, the Parties shall authorise the persons concerned to stay in their territory. 2 During this period, the persons referred to in paragraph 1 of this Article shall be entitled to the measures contained in Article 12, paragraphs 1 and 2. 3 The Parties are not bound to observe this period if grounds of public order prevent it or if it is found that victim status is being claimed improperly. Article 14 – Residence permit 1 Each Party shall issue a renewable residence permit to victims, in one or other of the two following situations or in both: a the competent authority considers that their stay is necessary owing to their personal situation; b the competent authority considers that their stay is necessary for the purpose of their co- operation with the competent authorities in investigation or criminal proceedings. 2 The residence permit for child victims, when legally necessary, shall be issued in accordance with the best interests of the child and, where appropriate, renewed under the same conditions. 3 The non-renewal or withdrawal of a residence permit is subject to the conditions provided for by the internal law of the Party. 4 If a victim submits an application for another kind of residence permit, the Party concerned shall take into account that he or she holds, or has held, a residence permit in conformity with paragraph 1. 5 Having regard to the obligations of Parties to which Article 40 of this Convention refers, each Party shall ensure that granting of a permit according to this provision shall be without prejudice to the right to seek and enjoy asylum. Article 15 – Compensation and legal redress 1 Each Party shall ensure that victims have access, as from their first contact with the competent authorities, to information on relevant judicial and administrative proceedings in a language which they can understand. 2 Each Party shall provide, in its internal law, for the right to legal assistance and to free legal aid for victims under the conditions provided by its internal law. 3 Each Party shall provide, in its internal law, for the right of victims to compensation from the perpetrators. 4 Each Party shall adopt such legislative or other measures as may be necessary to guarantee compensation for victims in accordance with the conditions under its internal law, for instance through the establishment of a fund for victim compensation or measures or programmes aimed at social assistance and social integration of victims, which could be funded by the assets resulting from the application of measures provided in Article 23. Article 28 – Protection of victims, witnesses and collaborators with the judicial authorities 1 Each Party shall adopt such legislative or other measures as may be necessary to provide effective and appropriate protection from potential retaliation or intimidation in particular during and after investigation and prosecution of perpetrators, for: a Victims; b As appropriate, those who report the criminal offences established in accordance with Article 18 of this Convention or otherwise co-operate with the investigating or prosecuting authorities; c witnesses who give testimony concerning criminal offences established in accordance with Article 18 of this Convention; d when necessary, members of the family of persons referred to in subparagraphs a and c. 2 Each Party shall adopt such legislative or other measures as may be necessary to ensure and to offer various kinds of protection. This may include physical protection, relocation, identity change and assistance in obtaining jobs. 3 A child victim shall be afforded special protection measures taking into account the best interests of the child. 4 Each Party shall adopt such legislative or other measures as may be necessary to provide, when necessary, appropriate protection from potential retaliation or intimidation in particular during and after investigation and prosecution of perpetrators, for members of groups, foundations, associations or non-governmental organisations which carry out the activities set out in Article 27, paragraph 3. 5 Each Party shall consider entering into agreements or arrangements with other States for the implementation of this article. Chapter VIII – Relationship with other international instruments Article 39 –Relationship with the Protocol to prevent, suppress and punish trafficking in persons, especially women and children, supplementing the United Nations Convention against transnational organised crime This Convention shall not affect the rights and obligations derived from the provisions of the Protocol to prevent, suppress and punish trafficking in persons, especially women and children, supplementing the United Nations Convention against transnational organised crime, and is intended to enhance the protection afforded by it and develop the standards contained therein. Article 40 – Relationship with other international instruments 1 This Convention shall not affect the rights and obligations derived from other international instruments to which Parties to the present Convention are Parties or shall become Parties and which contain provisions on matters governed by this Convention and which ensure greater protection and assistance for victims of trafficking. 2 The Parties to the Convention may conclude bilateral or multilateral agreements with one another on the matters dealt with in this Convention, for purposes of supplementing or strengthening its provisions or facilitating the application of the principles embodied in it. supplementing or strengthening its provisions or facilitating the application of the principles embodied in it. 3 Without prejudice to the object and purpose of the present Convention and without prejudice to its full application with other Parties, Parties which are members of the European Union shall, in their mutual relations, apply Community and European Union rules in so far as there are Community or European Union rules governing the particular subject concerned and applicable to the specific case. 4 Nothing in this Convention shall affect the rights, obligations and responsibilities of States and individuals under international law, including international humanitarian law and international human rights law and, in particular, where applicable, the 1951 Convention and the 1967 Protocol relating to the Status of Refugees and the principle of non-refoulement as contained therein.
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