ATC220906: Report of the Portfolio Committee on Women, Youth and Persons with Disabilities on the Commission for Gender Equality Report on Government’s Emergency Response Action Plan (ERAP) on Gender-based Violence and Femicide dated, 6 September 2022

Women, Youth and Persons with Disabilities

Report of the Portfolio Committee on Women, Youth and Persons with Disabilities on the Commission for Gender Equality Report on Government’s Emergency Response Action Plan (ERAP) on Gender-based Violence and Femicide dated, 6 September 2022

 

The Portfolio Committee on Women, Youth and Persons with Disabilities having considered the Commission for Gender Equality’s Report on Government’s Emergency Response Action Plan (ERAP) on Gender-Based Violence and Femicide on 23 February 2022 referred to it on 15 April 2021, reports as follows:

 

1.      Introduction

 

The Portfolio Committee on Women, Youth and Persons with Disabilities was briefed by the Commission for Gender Equality (CGE) on the Report on Government’s Emergency Response Action Plan (ERAP) on Gender-Based Violence on 23 February 2022.

 

2.         Mandate of the Department of the Commission for Gender Equality

 

The CGE’s work emanates from Section 181 of the Constitution (1996) and it is one of the Chapter 9 institutions which are independent entities for strengthening democracy. The CGE is therefore required to report to the National Assembly at least once a year regarding the progress of carrying out its strategic objectives. Section 187 of the Constitution stipulates that the Commission should promote respect for gender equality, and protect and develop its attainment, as well as monitor, educate, lobby, advise and report on issues related to gender equality.

 

In line with the CGE’s obligation to strengthen constitutional democracy with a focus on the attainment of gender equality, the CGE has a legislative mandate and functions which include the following:

 

1. Monitor, evaluate and make recommendations on:

• Policies and practices of organs of state, statutory bodies and functionaries, public bodies or private businesses, to promote gender equality.
• Any existing law including indigenous law and practices.
• Government’s compliance with international conventions with respect to gender equality.

 

1. Propose/recommend on:

• New law that may impact on gender equality or the status of women.

 

1. Develop, conduct or manage

• Educational strategies and programmes that foster understanding about gender equality and the role of the CGE.

 

1. Investigate and resolve conflicts

• On gender matters and complaints through mediation, conciliation and negotiation or referral to other institutions.

 

1. Liaise and interact

• With institutions, bodies or authorities with similar objectives to the Commission.
• With any organisation which actively promotes gender equality and other sectors of civil society to further the objectives of the Commission.

 

1. Prepare and submit reports

• To Parliament on aspects relating to gender equality.

 

In addition, the Commission for Gender Equality may:

 

• Conduct or order research to be conducted;
• Consider recommendations, suggestions and request from any source.

It is on this basis that the ERAP report was produced and tabled in Parliament for consideration.

 

3. Presentation by the Commission for Gender Equality on the Report on Government’s Emergency Response Action Plan (ERAP) on Gender Based Violence

 

3.1 Background

 

 Government’s Emergency Response Action Plan (ERAP) on gender-based violence and femicide (GBVF) came about as a response y Government to country wide calls from the public for urgent action against “what was perceived as a national crisis – the brutal killings of women and girls, and heightened violations of their rights in South Africa. These calls were part of a chorus of societal appeals from the gender sector for the authorities to act urgently and decisively to combat the high rates of domestic violence, intimate partner violence, rape, assaults and murder of women and girls that were perceived as spiralling out of control.”[1] The Presidential announcement of ERAP initiative was made on 18 September 2019. Moreover, the President of the Republic of South Africa pledged R1,6 billion to fund the Government’s ERAP initiative. The ERAP was a six-month national initiative with the following 5 key thematic Outcomes:

 

•  Access to justice for victims and survivors:
• Change norms and behaviour through high level prevention efforts.
• Urgent respond to victims of gender based violence
• Urgently respond to victims of gender-based violence (GBV)
• Strengthened accountability and architecture to adequately respond to scourge of gender based violence.

The President commissioned the Interim Steering Committee on Gender Based Violence and Femicide to prepare an ERAP. This plan commenced in October 2019 for a period of six months ending on 31 March 2020.

 

 

 

3.2 Aim of the study

 

The aim of the study was to assess/evaluate the extent of progress in the implementation of ERAP interventions and targets.

 

3.3 Methodology

 

The study to the form of a post-hoc review and assessment on the performance of state entities that were expected to give effect to ERAP over a 6-month period. It adopted an auditing approach as it involved obtaining performance information to measure actual performance against stated targets as specified in the government's original ERAP document. Hence the assessment of performance information from the implementing agencies i.e. (government departments, related agencies and other institutions) against ERAP responsibilities and targets as follows:

 

• Total of 39 specified interventions
• Total of 80 specified targets
• Total of 22 Government Departments
• Other entities such as labour unions, political parties, non-state actors, etc. were assigned responsibilities.

 

The review was based on reliable and accurate performance information collected and compiled by government departments and related entities (i.e. official reports and documents) to assess actual performance against ERAP targets. The CGE noted that “the accuracy and reliability of such information remains the responsibility of the state departments and agencies responsible for collecting such information and reporting on their progress. However, where documented information was limited or unavailable, the CGE sought to augment it by searching for alternative sources such as online databases, and interviews with departmental and other officials who were willing to be interviewed to provide further information and clarity on the work of their departments and agencies.”[2] To this end, the Commission also drew on a report released by the Interim Steering Committee (ISC) on GBV on ERAP in April 2020 which assisted in compiling its research report.

 

3.4 Limitations of the Study

 

The Commission highlighted the following challenges, constraints and or limitations in conducting the review:

 

• Review/assessments was carried out during emergency/lockdown restrictions related to Covid -19 pandemic.
• Access to government department departments/officials for information was affected by lockdown restrictions.
• Reluctance/delays by officials from some government departments in providing information
• Issues of reliability and accuracy of information provided by departments.
• Abolition of the Interim Steering Committee on GBVF also affected access to vital information on progress relating to ERAP initiatives

 

4. Findings of the study

 

The findings of the study were reported on in terms of general observations i.e. overview of implementation of ERAP and then by thematic area 1-5 each of which is outlined hereafter.

 

4.1 ERAP: Overview of implementation

 

• ERAP was a timely, necessary and crucial national response to an urgent national crisis.
• Responsibilities for implementation interventions programmes and related activities were assigned to various government departments and other entities.
• The ISC had overall responsibility for ensuring coordination, oversight and accountability of implementing agencies
• The ISC also had responsibility for key decision making such as goal setting, prioritisation, determining strategic direction, focus and funding levels for programme interventions/activities.
• The ISC was also responsible for liaisons with funders/donors, CSOs and for reporting/accounting to parliament.
• The overall implementation of ERP was characterised by inadequate operational coordination of departmental activities across thematic areas, intervention and targets.
• The thematic areas placed greater emphasis on long term qualitative policy outcomes for the country for dealing with gender-based violence. However, the accompanying targets tended to place greater emphasis on short term-quantitative outputs without clear linkages to long term qualitative outcomes implied in the 5 Thematic areas.
• Many of the ERAP targets appeared not to be based on a clear assessment of existing institutional capacity needs of responsible departments or entities and this resulted in many targets not achieved due to the scope of the work involved exceeded existing institutional capacity.
• The original ERAP document did not make provision for the systematic ongoing monitoring and evaluation assessment of progress in the implementation of intervention and targets.
• ERAP planners did not provide a mechanism for post implementation impact assessment regarding the 39 interventions and 80 targets relating to the thematic areas.
• The ISC issued its own ERAP report in April 2020, which was a progress update and not a monitoring and evaluation report.

 

4.2 Findings on ERAP thematic overview

 

4.2.1 Thematic area 1 - Access to Justice for Victims and Survivors

 

The purpose of this thematic area was to improve access to justice for victims and survivors (both and long term goals). The following departments/entities were assigned responsibilities under this theme:

 

• Department of Justice & Correctional Services
• Department of Social Development
• Department of Women, Youth and Persons with Disabilities
• National Prosecuting Office
• Presidency
• Parliament

 

The overall performance information for the intervention and targets was largely characterised by issues of accuracy and reliability. It was also found that many of the claims of achieved targets could not be verified based on information provided by departments especially department such as SAPS. The information contained in the ISC on GBVF’s report had limited information for assessing claims of progress and achievements as well. Notwithstanding that, key highlights for this thematic area was indicated as follows:

 

• The Department of Justice & Correctional Services developed the following:

 

• Sexual Offences/Criminal Law Amendment Bill
• Domestic Violence Bill
• Criminal Matters (Bail and Sentencing) Amendment Bill

 

• In terms of SAPS (Liquor establishment compliance inspections)

• 84 023 establishments were inspected
• 1, 310 illegal outlets were closed down

 

Key targets that were not achieved for this thematic area were indicated as follows:

 

• Establishment of the national coordinating structure on gender based violence.
• Vetting of all state personnel working directly with children and the mentally disabled (only a small number of personnel vetted). The focus of this intervention was vetting against the sexual offences register. In addition, what was also noted was a lack of skills training, expertise, care and funding.
• Overall many targets under this thematic area were not achieved.

 

4.2.2 Thematic Areas 2 - Change norms and behaviour through high level prevention efforts

 

• This thematic area placed great emphasis on changing behavioural norms in areas such as the workplace, schools, etc. in the long term. Such long term behaviour changes were more likely to happen over a longer time frame beyond the ERAP 6-month period.

• The ISC ERAP progress update report did not provide much useful information and insights into progress and achievements relating to ERAP targets under this intervention.
• Several lead institutions responsible for various targets under this intervention were approached during this exercise to provide additional information regarding their activities, progress and achievements. These included the Department of Arts and Culture (DAC), the South African Broadcasting Corporation (SABC), Government Communication and Information System (GCIS) and the ISC.  However, these institutions failed to provide the information requested by the time this report was compiled.
• Notwithstanding that, even though the ISC's ERAP report states that the DWYPD had launched the 365-day sustained campaign to prevent GBV 25 in partnership with the United Nations and a company called First for Women, the details of this campaign were not clear. In addition, it was also not clear whether this constituted a multi-media campaign to prevent and condemn GBVF and if it was executed by November 2019, according to the targets outlined in the original ERAP document.
• Furthermore, no information was made available to determine if targets under this intervention were achieved satisfactorily.

• Some departments such as Department of Higher Education and Basic Education provided comprehensive information on progress achieved especially educational campaign in schools around prevention.  For example, campaigns in schools need to be sustained over longer time periods to be effective and for greater impact in the long term.
• Similarly, campaign interventions to change behavioural norms in the workplace (e.g. by the Department of Labour) also need longer time frames than 6 months to take effect and be sustainable in longer term.
• This was also characterised by claims based on inadequate information from some of the departments.

 

4.2.3 Thematic Area 3 - Urgently Respond to Victims of GBV

 

• The focus of this thematic area was on short term urgent interventions and responses to the needs of victims of gender based violence by firstly; providing access to emergency support services through improved responses and secondly; improving effectiveness of support system, processes and practices aimed at urgent needs of victims of gender based violence.
• The Departments responsible for implementation of this thematic area were as follows:

 

1. Department of Health
2. NPA
3. Department of Public Works and Infrastructure
4. Department of Public Service and Administration
5. CoGTA
6. South African Police Services

 

• These departments provided insufficient information on their progress on ERAP target achievements.
• Many targets under this thematic area were not achieved or only partially achieved with insufficient explanation provided as to why this was the case. Overall pointing to a lack of accountability. An example cited was The Department of Social Department and Department of Public Service and Administration’s target was to recruit 650 social workers by 1 December 2019. However, only 200 Social Workers were recruited later than the stated time-line (30 March 2020).
• The NPA’s recruitment of 74 Prosecutors target was noted as a highlight as it exceeded the target of 50.

 

4.2.4 Thematic area 4 - Strengthen Accountability Architecture to Adequately Respond to the Scourge of GBV

 

• This thematic area entailed medium and long term goals and the lead department to implement was the Department of Women, Youth and Persons with Disabilities and ISC on GBVF.
• The performance against this area was poor and that not a single target met was satisfactory.
• Overall targets and time frame set were unrealistic.
• There was lack of interdepartmental collaboration/coordination and poor resource allocation played an important role.
• The key interventions that were not achieved by this thematic area was the establishment of a national coordinating mechanism on GBV which was meant to serve as an accountability mechanism on combating GBV.

• The responsibility of establishing a multi-sectoral coordination and accountability structure on GBVF was assigned to the Department of Women, Youth and Persons with Disabilities (DWYPD) as well as the Interim Steering Committee on Gender-Based Violence and Femicide (ISC-GBVF). This task had not yet been completed by 31 March 2020.
• The CGE’s key finding was that the task of establishing the multi-sectoral coordinating body on GBVF was given to two different institutions on two separate occasions, each with a six-month time period to complete the task, and on both occasions, the target was not achieved.

• In terms of the Rapid Response Teams their establishment and capacity development, very little information was provided by the lead institutions responsible for performance information on this target. Available performance information on this target was vague and incomplete, suggesting that very little was accomplished. For instance, the information does not provide insights into aspects such as the capacity development of the RRT.
• In terms of the Provincial emergency teams established, based on information obtained from the Department of Women, Youth and Persons with Disabilities (hereafter the Department), the Department indicated that by July 2020, the department was still working on the establishment of provincial emergency teams to provide rapid and comprehensive responses to all forms of violence against women. The teams would comprise officials from the SAPS, DSD, DOH, DOJ&CD, DBE as well as members of civil society organisations. The report also refers vaguely to work being carried out to strengthen the provincial approach with the Premier's Office in the Eastern Cape. There was however no clarity regarding progress made by the other eight provinces. This lead to the CGEs conclusion that the target was not achieved.
• Some of interventions sought to forge greater inter agency collaboration by establishing Task Teams at national provincial levels. These Inter Agency Task Teams were aimed at facilitating provision of urgent support services for victims of GBV. However, such inter agency Task Teams appeared to have had limited success.
• This intervention also made provision for the establishment of a multi-sectoral GBVF fund to fund the activities of civil society organisations providing relevant services on the ground. The responsibility for this rested with the Department of Women, Youth and Persons with Disabilities, National Treasury and the ISC which was subsequently disbanded in April 2020.
• Based on the information obtained from the Department Women, Youth and Persons with Disabilities, on 13 December 2019 the department approved the appointment of a private sector-led initiative called the South African Business Coalition on Health and Aids (SABCOHA) as the agency to establish and be in charge of a fund account into which funds were to be donated by the private sector as part of this intervention. According to information obtained from multiple sources from both government and civil society organisations by the CGE, it appeared that SABCOHA was to operate this fund in line with the terms of reference crafted by the ISC. The CGE also became aware that this account was intended to receive funds donated by private sector donors towards ERAP-related activities. However, it was not clear whether or not this account was indeed established, if funds were donated by the private sector into the account, and what the balance of funds in the account was by the time the ERAP came to an end in March 2020.
• Furthermore, the CGE noted that it was not clear if the SABCOHA fund bore any relationship to the target (multi-sectoral GBVF fund) as stated under this intervention, given that the responsibility to establish such a fund was assigned to the National Treasury, the DWYPD and the erstwhile ISC. Also, the issue of which institution (between NT, DWYPD and ISC) was ultimately accountable for the ERAP-related funds donated by the private sector into the account administered by SABCOHA remains unanswered.
• Observations on the ground revealed that the entire process relating to the setting up of the GBVF Fund was marred with controversy as the appointment of SABCOHA had caused divisions among key civil society organisations and saw the National Treasury seeming to distance itself from the process.
• According to the CGE, some of the disgruntled members of civil society organisations cited what they perceived as irregularities in procedures undertaken to appoint SABCOHA, while others dismissed SABCOHA on the grounds of lack of experience in dealing with GBVF issues. Some of the critics pointed out that SABCOHA was more established on issues of HIV/AIDS rather than GBV. In addition, the National Treasury argued that existing legislative provisions could not permit it to disperse state funds through a voluntary agency like SABCOHA.
• It is, however, still unclear how the R1.6 billion funds committed by the President towards the ERAP were to be raised and dispersed for the implementation of the plan. Conflicting statements from key role players on the ground made it impossible for the CGE to obtain clarity on this issue.
• The ISC's ERAP report stated that once the national coordinating structure on GBV was established, the matter of the 65 GBVF fund will be placed on its agenda for finalisation. In terms of whether the target was achieved or not in this regard, a close look at the target revealed that the GBVF fund was meant to be multi-sectoral and was expected to support civil society and grassroots organisations providing GBV services by 31 March 2020. While an account was set up through SABCOHA, the status and functionality of the fund could not be vouched for by the CGE, leading to the conclusion that the target was not met.
• In terms of the percentage of legislators trained, according to the CGE available information, including the ISC's ERAP report, indicated that the training of legislators had not yet been carried out at the time the report was compiled. The Department of Women, Youth and Persons with Disabilities also indicated in July 2020 that the process was at the planning stage and that the department was working in partnership with the United Nations Office on Drugs and Crime (UNODC) to roll out the training. Further details pertaining to the training and related plans were not shared with the CGE. Therefore, this target was not achieved.

 

4.2.5. Thematic area 5 - Prioritise Interventions that Facilitate Economic Opportunities to Address Women’s Economic Empowerment

 

• The goal of this thematic area was the provision of economic opportunities for women and girls i.e. short term goals.  In addition, the goal was to address underlying structural economic causes (long and short term) to empower women and girls.
• The leading departments and role players to implement this were, National Treasury, Department of Employment and Labour, Department of Rural Development and Land Reform, organised business and other entities such as labour unions and political parties.

• The performance under this thematic area was unsatisfactory both in short and long term targets. The short term targets specified included:

 

1. Verify existed of relevant policies in the workplace (sexual harassment).
2. Creating job opportunities for women and girls.
3. Introducing preferential procurement policy quotas (40%) in favour of women.

• In response to CGE requests for its performance information regarding the target, 100% GBV survivors linked to economic opportunities, the Department of Employment and Labour stated that its legislative mandate entails the development and implementation of policy on the prevention and elimination of violence and harassment, including sexual harassment, in the workplace. Hence this department was adamant that the creation of economic opportunities for survivors of GBVF do not fall within its mandate. It would appear therefore that this was a misalignment of responsibility in relation to the target.
• With respect to the targets pertaining to sexual harassment policies in the workplace and related workplace strategies, the Department of Employment and Labour insisted that this target could only be achieved once the final 'Code of Good Practice on the Prevention and Elimination of Violence and Harassment in the World of Work' was published in the fourth quarter of the 2020/2021 financial year. Therefore, the target was not achieved.
• In terms of the Land reform programmes and targets for women beneficiaries, the CGE noted that this programme entails potentially complexed policy, legal and administrative process that went beyond the ERAP 6-months lifestyle. There was not much evidence of progress achieved in terms of the land reform programme during ERAP 6 months’ lifecycle. 
• In terms of the National budget re-orientation (Gender Responsive budgeting), the Gender Responsive Budget Framework (GRBF) initiative was already on the agenda of the Department of Women, Youth and Persons with Disabilities, still under way and was experiencing difficulties and needed greater cooperation of all key national ministries and greater national political will/leadership. For gender responsive budgeting to take effect, it needs a significantly longer time frame to introduce and institutionalise across government. The GRBF process is still under way, experiencing difficulties CGE has conducted a study in this regard.
• In terms of the target of preferential procurement, CGE was unable to obtain information on progress in terms of this target. The National Treasury indicated that it was not involved in the drafting of the ERAP document and was thus unable to assist in this regard. There was insufficient information to determine whether this target was achieved or not.
• Overall the performance of departments under this Thematic Area was unsatisfactory (both in short term and long term interventions).

 

4.2.6 Summary of achievements of targets

 

Of the 80 targets outlined in the ERAP, 17 (21.25%) were achieved, whilst, 12 (15%) were partially achieved and 51 (63.75%) targets were not achieved. The CGE indicated that the ERAP was a timely and appropriate response to an urgent national crisis but its implementation faced many obstacles on the ground. It also concluded that there were, firstly, problems of lack of effective coordination; secondly, ineffective oversight and accountability and thirdly, a lack of ongoing programme monitoring and evaluation mechanisms which led to many targets and interventions not achieved. Furthermore, the CGE indicated that the ISC’s coordinating role was crucial, but it was undermined by significant operational issues, including lack of role clarification, poor accountability and limited capacity. A large number of departments involved in the implementation of ERAP interventions were without effective operational coordination and collaboration across thematic areas.

 

5. Recommendations by the CGE

 

The CGE recommended the following:

 

1. That government undertakes at thorough review and evaluation of the implementation of the ERAP to identify achievement of the various targets and identify the challenges encountered during implementation of the plan. The findings of this review and evaluation should be made public.
2. The review and evaluation of the ERAP, as contemplated above, should be carried out by a competent and independent service provider, with the view to identifying key challenges, lessons learned and prospects for continued implementation of some of the key interventions and critical targets with potentially long-term timeframes and positive consequences in the fight against gender-based violence.
3. Given that the Interim Steering Committee on GBVF was abolished in April2020, it is recommended that in the short to medium term, the overall responsibility to drive government’s programmes of intervention to deal with GBVF be placed under a competent institutional structure or department that will oversee such national programmes including the process of establishing the national multi-stakeholder body on gender-based violence.
4. That priority, including the necessary resources, be given to the current process of establishing the national multi-stakeholder body on gender-based violence and femicide. It is further recommended that the necessary legislative process be initiated to ensure that such a multi-stakeholder national coordinating body on gender-based violence has the requisite legal standing and access to regular funding. The Commission for Gender Equality, as a critical stakeholder, should engage with the Ministry for Women in the Presidency and other relevant stakeholders regarding planning processes and time frames for the establishment of the national multi-stakeholder coordinating body on GBVF.
5. The National Strategic Plan (NSP) has been approved by Cabinet. Implementation of the NSP should be the responsibility of the national multi-stakeholder coordination body that is yet to be established. Therefore, while the process of establishing the multi-stakeholder coordinating body on GBVF is still underway, it is recommended that the responsibility for the implementation of the NSP be placed under the Ministry for Women in the Presidency.
6. It is recommended that the Ministry for Women in the Presidency should initiate a consultative process for planning, costing/budgeting, implementation, monitoring and evaluation of the NSP and report progress to Parliament. This responsibility should reside with the Ministry for Women in the Presidency until such time as the national multi-stakeholder coordinating body on GBV is ready to assume the role and execute these functions. It is further recommended that the Commission for Gender Equality engages with the Ministry for Women in the Presidency regarding planning processes and timeframes for implementation of the NSP.
7. One of the key interventions identified in the ERAP was the implementation of the Gender Responsive Budget Framework introduced by the Ministry for Women in the Presidency and approved by Cabinet in 2019. It is recommended that this framework be widely disseminated and popularised across government (at national, provincial, and local government levels). It is further recommended that the National Treasury plays a leading role in ensuring that the framework is adopted and implemented.
8. As part of its constitutional and legislative mandate, the Commission for Gender Equality should continue to assess government’s implementation of national policy and legislative frameworks, including national strategies (e.g. NSP, GRPB, etc.) and programmes of action (e.g. Presidential Summit Declarations, ERAP) to combat gender-based violence. This should be done, among others, through direct and regular engagements between the leadership of the Commission and relevant government departments.

 

6.   Committee Observations

 

 The Committee having deliberated on the CCGE’s the report, made the following observations:

 

1. The Committee was concerned that not enough time was allocated to implement the ERAP Plan and as such this impacted the outcome.
2. The Committee queried what progress had been made since the CGE last presented to the Committee on the report given that the country’s focus was now on the implementation of the National Strategic Plan on Gender-Based Violence and Femicide as well as the establishment of the Council.
3. The Committee enquired about the challenges the CGE experienced in the development of the report and with the implementation of the recommendations.
4. Given the time constraints and various levels of assistance received from departments by the CGE, the Committee asked what assistance the CGE required from the Committee to ensure the recommendations are implemented.

 

 

 

 

5.       Recommendations

 

The Committee having interacted with the Commission for Gender Equality on the report, made the following recommendations:

 

1. The CGE should ensure that they monitor all government departments that are responsible for implementing the National Strategic Plan (NSP) on Gender Based Violence and Femicide (GBVF).
2. The Committee should engage with the Secretariat of the National Council on Gender-Based Violence on Gender Based Violence and Femicide (NCGBVF) on their role and programme to implement the NSP on GBVF.

 

 

6. Conclusion

 

The Committee welcomed the report by the CGE and acknowledged the importance of monitoring and evaluating policies to address gender-based violence and femicide in the country. Furthermore, the Committee committed to a joint meeting with relevant Portfolio Committees in order to engage with relevant departments and assess what progress has been made insofar as the implementation of the NSP on GBVF is concerned in addition to the recommendations outlined by the CGE in its report.

 

 

Report to be considered.

 

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[1] Commission for Gender Equality (2020) Government’s Emergency Response Action Plan on Gender-Based Violence and Femicide, Commission for Gender Equality Review of Implementation, p.5.

[2] Ibid, 12