Publications

Submission to the Council of Europe European Commission Against Racism and Intolerance - Parallel Report for the Sixth Cycle in Monitoring the United Kingdom

Date produced May 2023.

Below is a summary of our recommendations and messages.

You can also download the full document through the links provided.

2.11 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures that sufficient and sustainable long-term funding is provided to enable the NIHRC to fulfil its statutory functions independently in line with its role as an A status institution under the UN Paris Principles.

3.3 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive conducts a review of the operation of the Addressing Bullying in Schools (NI) Act 2016 to examine its effectiveness at addressing the impact and prevalence of bullying in NI schools with immediate steps taken to address and monitor the findings of the review.

3.4 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that bullying experienced by particular groups of children in NI, such as by lesbian, gay, bisexual, transgender, queer (or questioning) and intersex+ pupils and children from ethnic minorities is addressed. This includes ensuring that children, all teachers and other education providers are trained on how to identify, address and remedy the impacts of bullying, including online bullying.

3.5 The CoE European Commission Against Racism and Intolerance may wish to advise the NI Executive to embed consideration of Windsor Framework Article 2 in relation to bullying of minority ethnic children in schools and to monitor any proposed changes by the EU following the ongoing consultation by the EU on the EU Racial Equality Directive, as well as relevant CJEU case law, in line with the ‘keeping pace’ obligations under Windsor Framework Article 2.

3.13 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive, as a matter of priority, expeditiously agrees and makes provision for the funding required to implement the action plan based on the Expert Panel on Educational Underachievement in NI’s findings. In the interim, the Department of Education NI should take steps, where it is not able to address issues in their entirety in the absence of an NI Executive, to ensure these issues are not exacerbated by the delay.

3.14 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly updates and publishes its proposals for the revised policy for children of migrant families, including an action plan that will guide its effective implementation. This should take a human rights-based approach in line with international human rights standards and Windsor Framework Article 2. It should also include reconsidering the use of the term ‘newcomer pupils’.

3.15 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that teacher training that promotes cultural awareness is developed and delivered within schools and considers ways to provide a curriculum bespoke to pupils’ specific needs and experiences. This should include meaningfully consulting with parents, guardians, children and representative organisations at every stage of the process.

3.16 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive urgently reviews and adequately funds the Education Authority NI's Intercultural Education Service. The resulting process and funding should have sufficient flexibility built in to ensure all children seeking asylum in NI at any given time have timely access to education and other necessary supports, such as language classes, uniform grants, school meals and transport.

4.11 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government repeals the Memorandum of Understanding with Rwanda and ensures all people seeking asylum in the UK are processed in a human rights’ compliant way. This should take into account the trauma likely to have affected people prior to and during the journey to the UK.

4.22 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government revises the Illegal Migration Bill to ensure that the foundational human rights principles of inalienability, universality and proportionality are embedded throughout, including in the language used, to prevent the demonisation and unjustifiable denial of human rights protection to particular groups of migrants.

4.23 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government takes steps to ensure that the Illegal Migration Bill complies with Article 2 of the Windsor Framework and that the Human Rights Memorandum to the Bill be amended to set out in detail an assessment of the compliance of the Bill with Article 2 of the Windsor Framework.

4.24 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government, through meaningful engagement, immediately and thoroughly assesses the purpose and provisions of the Illegal Migration Bill. The result should ensure that all refugees, people seeking asylum and migrants arriving to the UK are processed, accommodated and supported in compliance with human rights obligations, with particular focus on if, when and how individuals are transferred to a third country. It should also ensure that continued access to domestic courts for human rights violations is ensured.

4.29 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government and the NI Executive urgently review the support and accommodation provided to refugees and people seeking asylum in NI to ensure it is adequate, fit for purpose and culturally appropriate in compliance with international human rights standards and Windsor Framework Article 2. This review should be conducted in consultation with refugees, people that are seeking asylum and their representative organisations.

4.30 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive develops appropriate safeguards through statutory regulations and guidance to ensure the enactment of the Nationality and Borders Act 2022 does not have a negative effect on refugees and people seeking asylum.

4.31 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government and the NI Executive urgently develop and resource a realistic, long-term strategy aimed at expeditiously ending the use of hotels for contingency asylum accommodation in NI, particularly for families and persons with disabilities. The strategy should be culturally appropriate, take into account individual’s specific needs and be developed in consultation with refugees, people that are seeking asylum and their representative organisations.

4.39 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes effective steps to identify and minimise procedural barriers to migrant women accessing healthcare. This includes introducing guidance for healthcare professionals on providing effective access.

4.40 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive issues an amendment or policy direction to ensure that the full set of General Practitioner services, including access to a General Practitioner list (subject to discretion) is genuinely available to any person.

4.41 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government and NI Executive minimise any procedural or informational barriers to accessing healthcare services for people in temporary and contingency accommodation that are seeking asylum.

4.42 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government provides further guidance on the rights of people with pending and late applications to the EU Settlement Scheme, to applicants to the Scheme and to healthcare professionals to ensure no diminution of the current provision and protect the rights to the highest attainable standard of healthcare.

4.43 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive provides clear, accessible and complete information on rights to healthcare post-EU withdrawal, including access to cross-border and island-of-Ireland services to ensure no diminution of the current provision and protect the rights to the highest attainable standard of healthcare.

5.6 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive, promptly introduces legislation in NI to ban all practices of conversion therapy aimed at changing or suppressing a person’s sexual orientation or gender identity, by any person or group of persons. The NI Executive should be guided by the UN Independent Expert on protection against violence and discrimination based on sexual orientation and gender identity and the Expert Advisory Panel on a Lesbian, Gay, Bisexual, Transgender, Queer (or Questioning), Intersex+ Strategy for NI’s definitions of conversion therapy in developing this legislation and its broader work related to this issue.[1]

5.12 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive introduces clear guidance that provides legal certainty for businesses and customers on what constitutes discrimination. This guidance should address specifically the nature of the right and its key principles.

5.13 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that the Hate Crime Review Team’s recommendations on homophobic hate crime are promptly implemented in full and that the NI Executive considers carefully and ensures compliance with Windsor Framework Article 2, including the provisions of the EU Victims' Directive in the development of hate crime legislation.

5.14 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly publishes and implements a robust and adequately resourced Lesbian, Gay, Bisexual, Transgender, Queer (or Questioning), Intersex+ Strategy for NI which takes a human rights-based approach in line with international human rights standards and Windsor Framework Article 2. This strategy should be accompanied by a measurable plan of action and effective monitoring mechanisms.

5.16 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly publishes and implements a robust, gender-sensitive Gender Equality Strategy, which takes a human rights-based approach in line with international human rights standards and Windsor Framework Article 2. This strategy should be accompanied by a measurable plan of action and effective monitoring mechanisms.

5.21 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly publishes and implements a robust and adequately resourced Lesbian, Gay, Bisexual, Transgender, Queer (or Questioning), Intersex+ Strategy for NI that deals with gender recognition and takes a human rights-based approach in line with international human rights standards and Windsor Framework Article 2. This strategy should be accompanied by a measurable plan of action and effective monitoring mechanisms.

5.22 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that the gender recognition process in NI is amended to reflect the self-declaration model. This process should be affordable, respectful and accessible, including effectively training staff and professionals across an individual’s gender recognition journey.

5.23 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that transgender children are effectively supported and that the best interests of the child are a primary consideration.

5.27 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government and NI Executive, facilitate the recognition of intersex individuals before the law through the expeditious provision of birth certificates, civil registration documents, identity papers, passports and other official personal documentation while respecting intersex persons’ right to self-determination.

5.28 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes all necessary measures to protect the right of intersex children to autonomy and bodily integrity and that all medical interventions have informed consent.

5.31 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that the housing selection scheme is revised to ensure that it considers properly an applicant’s circumstances and reflects up-to-date common challenges faced by individuals and households in NI, particularly in relation to intimidation points. This requires meaningful consultation with individuals affected and their representative organisations.

5.32 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that an official mechanism to appeal housing selection decisions is in place, which is effectively implemented and monitored. This includes ensuring the appeals process and its outcomes are promptly and effectively implemented.

5.33 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that comprehensive equality data on housing in NI is regularly gathered, monitored, evaluated and published. This data should be disaggregated in a way that reflects NI society. The NI Executive in cooperation with housing providers, Police Service NI and community representatives should take prompt, effective steps to address and eradicate any inequalities that are identified.

5.36 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive identifies, develops, implements and monitors effective measures to ensure perimenopausal and menopausal women have equal access to employment throughout their working life and the necessary support to ensure such access is practically available. Every stage of this process should be based on meaningful engagement with perimenopausal and menopausal women and their representative organisations. It should also involve consulting on revising equality legislation and policies to include menopause as a protected characteristic.

5.37 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes immediate steps to ensure perimenopausal and menopausal women have access to the medication and treatments that they need to treat their menopause symptoms on a long-term and affordable basis, with a view to supporting all women’s enjoyment of rights, including access to work.

5.48 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes prompt, concrete steps to fully implement the obligations on relationship and sexuality education set out in the NI (Executive Formation etc) Act 2019, in line with the UN CEDAW Committee’s recommendations.

6.7 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly and effectively improves hate crime legislation in NI, guided by the Independent Hate Crime Review Team’s recommendations and the Department of Justice’s consultations. The NI Executive should ensure that any new legislation compliments existing and future strategies on race and community relations.

6.8 The CoE European Commission Against Racism and Intolerance may wish to advise the NI Executive to consider carefully and ensure compliance with Windsor Framework Article 2, including the provisions of the EU Victims’ Directive, in the development of hate crime legislation and ensure that a victim-centred approach is adopted when investigating, prosecuting and remedying hate crimes.

7.5 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive introduces a Single Equality Act for NI and secures the necessary political consensus to deliver this.

7.6 The CoE European Commission Against Racism and Intolerance may wish to advise that the NI Executive monitors any proposed changes by the EU to the six Annex 1 Equality Directives, as well as relevant CJEU case law, and pay particular attention to the ongoing consultation by the EU on the Racial Equality Directive.

7.13 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures intersectional multiple discrimination claims in NI are effectively addressed, including providing for intersectionality within equality legislation as required.

7.14 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive Office monitors any proposed changes by the EU to the six Annex 1 Equality Directives, as well as relevant CJEU case law, and pay particular attention to the ongoing consultation by the EU on the EU Racial Equality Directive.

7.28 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes effective steps to ensure its data collection on racial equality is consistent, extensive and disaggregated. This includes working with the NI Assembly to promptly amend the Race Relations (NI) Order 1997 so that it imposes a duty on specified public authorities to collect data on racial equality and set racial equality objectives.

7.29 The CoE European Commission Against Racism and Intolerance may wish to advise that the NI Executive monitors any proposed changes by the EU to the six Annex 1 Equality Directives, as well as relevant CJEU case law, and pay particular attention to the ongoing consultation by the EU on the EU Racial Equality Directive, in line with the ‘keeping pace’ obligations under Windsor Framework Article 2.

7.30 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government, in the implementation of the revised guidance on the Common Travel Area and the European Travel Authorisation requirements, take effective steps to prevent and address racial profiling at entry to NI at ports and airports and in the context of cross-border travel. This should include effective gathering and monitoring of disaggregated data, including racial and ethnic monitoring, of people examined by enforcement officers. It should also include effective monitoring and provision of training to enforcement officers, including review mechanisms and disciplinary procedures in cases of racial profiling.

7.31 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures all journeys into NI, that originate from Ireland, are exempt from Electronic Travel Authorisation requirements.

7.32 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government monitors the impact of developments to facilitate goods coming into NI from Great Britain to ensure Muslim and Jewish communities in NI are able to access halal and kosher food products and ritual items respectively.

7.37 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive introduces a Refugee Integration Strategy that reflects the outcomes of the consultation process and the NI Affairs Committee’s inquiry and takes a human rights-based approach in line with international human rights standards and the Windsor Framework Article 2 without further delay. The final strategy should be accompanied by a comprehensive action plan and adequate, long-term resources.

7.38 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly develops, implements, monitors, and adequately funds public education and community integration initiatives across NI, which raise awareness about the issues facing people seeking asylum and refugees in order to tackle fear, stigma, and discrimination. This should be included as a commitment within the Refugee Integration Strategy.

7.45 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government urgently increases the level of financial support provided to people seeking asylum to reflect the rising cost of living across the UK.

7.46 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government to review the restrictions placed on people seeking asylum, which prevent the taking up of work while claims are being processed.

7.47 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensure that payments to people seeking asylum can be used online.

7.48 The CoE European Commission Against Racism and Intolerance may wish to advise the UK Government to embed consideration of Windsor Framework Article 2 with respect to financial support for asylum seekers in NI to ensure there is no diminutions of rights, including the provisions set out in the EU Reception Directive.

7.52 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive places the Crisis Fund on a permanent footing, with guaranteed funding.

7.53 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government and NI Executive address the causes of destitution in the first instance, rather than rely on a discretionary fund to address destitution when it emerges. The CoE European Commission Against Racism and Intolerance may also wish to recommend that the UK Government and NI Executive to introduce measures to guarantee targeted support to all those living in poverty or at risk of poverty, including people seeking asylum, refugees, migrants and other vulnerable groups.

7.60 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive to ensure the full implementation of the remaining recommendations in its investigation report. The CoE European Commission Against Racism and Intolerance may also wish to recommend that the NI Executive develops long-term strategies to ensure that implemented recommendations continue to be adhered to.

7.61 The CoE European Commission Against Racism and Intolerance may wish to advise the NI Executive to embed consideration of Windsor Framework Article 2 in its housing supply strategy and monitor any proposed changes by the EU to the six Annex 1 Equality Directives, as well as relevant CJEU case law, and pay particular attention to the ongoing consultation by the EU on the Racial Equality Directive.

7.65 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive, supported by the NI Assembly, ensures that the Unauthorised Encampments (NI) Order 2005 is promptly repealed.

8.14 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government recognises the Human Rights Act 1998 as a constitutional statute and ensures any reform builds on the 1998 Act as part of further progress in the promotion and protection of human rights.

8.15 The CoE European Commission Against Racism and Intolerance may wish to advise that the protections in Windsor Framework Article 2, while an important safeguard against the diminution of rights following UK withdrawal from the EU, are not a substitute for the comprehensive framework of human rights protections under the Human Rights Act.

8.31 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures that the Common Travel Area and rights associated with it are enshrined in domestic law. The CoE European Commission Against Racism and Intolerance may also wish to recommend that this agreement codifies reciprocal free movement rights and rights to employment, education, health care, justice and security to maintain the same level of protection as existed on 31 December 2020.

8.38 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive expeditiously introduces legislation to repeal all legal provisions permitting the marriage of children in NI and increase the minimum age for marriage to 18 years, for both girls and boys.

8.39 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures the Windsor Framework Article 2 is considered and complied with throughout the development of legislation and policy in relation to marriage law including changing the minimum age for marriage to 18.

8.40 The CoE European Commission Against Racism and Intolerance may wish to recommend that the cross-Departmental efforts within the NI Executive to combat forced marriages are strengthened, including by sensitising parents on the need for full and free consent of their child to marry.

8.45 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government, as a minimum, introduces a requirement to ensure judicial scrutiny before exercising the power to deprive an individual of their UK citizenship.

8.46 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government only utilises the power to withhold notice of a decision to deprive a person of British citizenship when it is absolutely necessary.

8.54 The CoE European Commission Against Racism and Intolerance may wish to recommend that measures are taken by the NI Executive to investigate and prosecute perpetrators of female genital mutilation. This includes implementing a prevention strategy and action plan, which includes increasing efforts to raise awareness, particularly within affected communities, that female genital mutilation is a form of both child abuse and gender-based violence against women and girls. It also includes ensuring specialised support is available and accessible to victims of female genital mutilation. The CoE European Commission Against Racism and Intolerance may also wish to recommend that that disaggregated data on the prevalence of female genital mutilation in NI is gathered and monitored.

8.55 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive considers and takes into account the EU Victims’ Directive and Windsor Framework Article 2 during the development and implementation of the Domestic Abuse Strategy and the Equally Safe Strategy.

8.63 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government withdraws its reservations against the Istanbul Convention.

8.64 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that support for domestic and sexual violence and abuse is available regardless of an individual’s immigration status, in line with international human rights standards and Windsor Framework Article 2.

8.65 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes immediate steps to ensure there are enough refuge places for those that need them, when they need them.

8.66 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that all policies and support for victims of domestic and sexual violence and abuse are specialised, accessible, gender-sensitive and guaranteed sustainable funding. Including that these factors are taken into account when commissioning services aimed at supporting victims and survivors. Also that the steps taken are guided by disaggregated data and meaningful engagement with victims, survivors and representative organisations.

8.73 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures effective, consistent implementation of the Short-term Holding Facility Rules 2018, including comprehensive training of all staff in Larne House on identifying and reporting torture, and the local services and safeguarding services available.

8.74 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures the independence of health care professionals dealing with detained asylum seekers.

8.75 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government takes prompt steps to amend the NI Act 1998 to allow the NIHRC to enter Larne House without having to provide advance notice.

8.89 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive promptly introduces legislation providing for Trafficking and Exploitation Risk Orders in NI. In line with international human rights standards and Windsor Framework Article 2, this guidance should require individual assessments of victims to be conducted for the purposes of identifying the necessity and proportionality of a risk order.

8.90 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that the root causes of human trafficking and exploitation are addressed. Trauma-informed, specialised, accessible support for victims of human trafficking and exploitation in NI should be sufficiently and promptly available when required, and adequately funded. This includes effective access to social security benefits and specific provision for specialised care and support for child victims of human trafficking, many of whom may have experienced complex trauma.

8.91 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government embeds consideration of Windsor Framework Article 2 in the development and implementation of subsequent Regulations and Guidance on human trafficking resulting from the Nationality and Borders Act 2022 and establishes processes to ensure compliance with this obligation. The CoE European Commission Against Racism and Intolerance may also wish to recommend that subsequent regulations and guidance should ensure the needs of child victims of modern slavery and human trafficking are safeguarded and the best interests principle is embedded.

8.92 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures that Windsor Framework Article 2 is built into and considered actively during the development and implementation of all legislation and/or policy; and that the Department continues to monitor relevant EU Directives and related CJEU jurisprudence to ensure there is no diminution of victims’ rights within the scope of Windsor Framework Article 2.

8.93 The CoE European Commission Against Racism and Intolerance may wish to recommend that, in line with international human rights standards and Windsor Framework Article 2, the NI Executive requires compulsory specialised training and guidance to all relevant staff, which is trauma-informed and victim-centred, to ensure victims are accurately identified and supported.

8.94 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive ensures trauma-informed specialist services which are adequately funded, inclusive and accessible, to assist women and girls to exit prostitution are practically available. Furthermore, the NI Executive should ensure women in vulnerable situations in NI have effective access to employment opportunities, housing and social security so that they are not vulnerable to prostitution or ‘sex for rent’.

8.95 The CoE European Commission Against Racism and Intolerance may wish to recommend that the NI Executive takes effective steps to reduce demand for commercial sex in NI, including by carrying out educational and awareness-raising measures targeted at men and boys and focused on combating all notions of subordination and objectification of women.

8.96 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government ensures policies and legislation, such as the Illegal Migration Bill, are human rights compliant, including that adequate support is accessible and available to all victims and potential victims of modern slavery and human trafficking.

8.97 The CoE European Commission Against Racism and Intolerance may wish to recommend that the UK Government considers and details its analysis of the compliance of the modern slavery provisions within the Illegal Migration Bill with Windsor Framework Article 2.

[1] It should be noted that one Commissioner at the NI Human Rights Commission dissented from this recommendation.