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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession, 2004


NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

October 2004, Sofia, Bulgaria

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

Contents 1. Key Recommendations

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2. Economic, Social and Cultural Rights

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Children's Rights The de-institutionalisation plan The exclusion of Special Schools from de-institutionalisation plan Administrative structure of the Child Protection System Capacity in child protection departments International adoption Trafficking of children People with Disabilities People with mental disabilities 3.

Minority Rights

6 6 7 8 9 10 10 11 12 13

Protection against Discrimination

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The Roma Minority

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Education Health Social Benefits System Employment

13 15 16 16

Other Minority Groups

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Publicly owned electronic media

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The National Council on Ethnic and Demographic Issues

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4. Civil and Political Rights

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Police Misconduct

18

Prison Conditions

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Juvenile Justice System

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Legal Aid

20

Asylum

20

Freedom of Expression

20

Religious Freedom

20

5. The Administrative capacity of the State

21

Staff Qualifications and de-centralisation

21

The Education Modernisation Project

22

6. The Role of NGOs

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7. Contacts

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

This report was produced by a coalition of Bulgarian-based NGOs with expertise in the area of social and human rights policy. It addresses a number of issues which were covered in the European Commission’s 2003 Regular Report on Bulgaria and which should be covered in the European Commission’s 2004 Regular Report, due to be published in early October 2004. The report is intended to provide a contribution to understanding of these key issues as Bulgaria nears EU accession and to provide an overall picture of the progress made, based on grass-roots experience and extensive research throughout Bulgaria.

1.

KEY RECOMMENDATIONS

Promoting respect for the human, civil and political rights of all Bulgarian citizens and improving living standards for Bulgaria’s most vulnerable groups should be at the heart of Bulgarian government policy. Only if this happens can a dignified Bulgaria join the European Union on an equal basis with other European countries. We call upon the Bulgarian government to prioritise investment and efforts on reform in the following areas:

Child welfare -

a more strategic effort, with dedicated finances, should be made to close children’s institutions: there are still some 31,000 children living in these on a temporary or permanent basis, many in terrible conditions

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adequate human and financial resources must be allocated to work on the prevention of abandonment and re-integration of children into families: the number of children entering institutions is not decreasing and there is a risk the system will not fundamentally change if needy families are not helped

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a massive increase in the number of professional social workers is vital for the development of alternative care services such as foster care: there are towns where one single social worker has responsibility for 11,200 residents, well below accepted standards elsewhere in Europe

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there should be one single, well-resourced Government body with the power to ensure that child welfare reform happens: currently five Ministries and two Agencies are involved, duplicating efforts, wasting resources and not providing a coherent, long-term vision for Bulgaria’s children

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

-

October 2004

a unified national register for children and adopters should be established for adoption in Bulgaria and there should be far greater transparency in the international adoption system, particularly in relation to the costs involved

People with disabilities children -

active programmes for accessibility of mainstream schools should be started and physically disabled children should be integrated in mainstream educational facilities (schools and kindergartens); supporting environment in schools should be made effective so that children with learning disabilities can be accommodated in there as well

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so-called ‘special schools’ should become part of the de-institutionalisation plan: a detailed plan for the training of special teachers to work in the mainstream environment should be developed by the Ministry of Education

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the flow of financial resources should be regulated so that money reaches children with special educational needs no matter where they are enrolled to study

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disability policies need to be more focused and better targeted: the larger and less clear the target group is, the less effective public policy measures are. For example, access to social benefits has to be redefined and the general ‘lost working capacity’ criteria should be supplemented with age, education, competence and abilities criteria

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less but better targeted rights based programmes aiming at inclusion of the disabled people are needed: if government subsidies become more transparent and easier to monitor, it will be easier to build upon success. At the moment there are numerous government programmes, preferences and subsidies which do not result in effective inclusion

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community services should be enriched with services for inclusion, in addition to welfare based services, relevant to the needs of disabled people: at the moment, disabled people encounter difficulties with the environment and experience marginalisation resulting in low educational and professional levels, unemployment and poverty

adults

Minority rights -

The package of legal guarantees should be completed for the full and sustainable implementation of minority rights. There is at the moment a piecemeal approach to bringing domestic legislation into line with international minority rights protection

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

standards, which arises sporadically from state obligations to international institutions and in response to advocacy pressure on a national level. The following is essential: • To amend the relevant texts in the Constitution to broaden the scope of minority rights guarantees; • To bring domestic legislation into line with the provisions of the Framework Convention for the Protection of National Minorities and other international standards and to ensure coordination between the domestic laws themselves. -

The government should elaborate and implement an Overall Integration Policy based on human/minority rights protection standards. What is currently referred to officially as minority integration in Bulgaria is a set of sporadic institutional measures, unrelated to these standards, with no clear commitments and without any involvement of society as a whole. An overall integration policy should outline: • The values and conceptual framework of the integration process; the balance in relations between institutions, minority communities and citizen organisations. • Short-term and long-term aims, objectives and activities; overall priorities and specific measures targeting particular minorities; • The obligations of the various institutions, interaction between them, coordination mechanisms and structures; • Sources of funding; • The consultation process, the criteria and procedures for monitoring and evaluation. –

The publicly-owned electronic media should be promoted as a mediator in increasing public sensitivity to minority issues. The public environment as a whole is insensitive to these issues and journalists fail to adhere to professional ethical standards when dealing with them. The following changes are necessary: • To improve legislation regulating the publicly-owned electronic media in the following directions: guaranteeing ethnicultural pluralism in their programming; regulating the participation of minority journalists in them; revising the status and functions of their regulatory body to guarantee its political independence; regulating publicity for the results of electronic media monitoring. • the publicly-owned electronic media should ensure adherence to professional journalistic standards for work on ethnic issues.

Civil and political rights The Government of Bulgaria should: -

make torture as defined by the UN Convention against Torture a specific crime in law and enforce this law against police and other public officials practicing torture

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establish an effective system of investigation of torture and inhuman and degrading treatment and punishment

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

-

bring the present legal framework allowing an excessive use of firearms by law enforcement officers into conformity with international standards

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bring conditions in prisons, and especially in the pre-trial investigation facilities, into conformity with the UN Standard Minimum Rules for Treatment of Prisoners and with the other relevant international standards. It should, more specifically close all underground facilities immediately

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further reform the juvenile justice system and either abolish the schools for delinquent children or reform them in a way they can meaningfully serve the needs of children who are in conflict with the law. The procedure for placement should pay due regard to due process standards

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establish a comprehensive system for provision of legal aid to indigent defendants in the penal process, as well as in the civil procedure

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further reform the Asylum Act and bring it into conformity with the UN Convention on Status of Refugees and ensure that the law is not applied arbitrarily

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establish by law a regulatory board on electronic media that is independent from political and commercial interests, works on the basis of professional standards and takes into consideration the independence of the media, as well as the public interest

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reform thoroughly the existing restrictive and discriminatory legal framework of church-state relations and ensure that the state mediates impartially between conflicting religious factions

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

2.

October 2004

ECONOMIC, SOCIAL AND CULTURAL RIGHTS

Children’s Rights The European Commission’s 2003 Regular Report (RR) noted significant progress in the legislative framework related to child welfare. The Child Protection Act (CPA), amended in April 2003, provides for special care for children with mental and physical disabilities and stricter rules for the placement of children outside the family. Secondary legislation underpinning the CPA has also been introduced. A large number of strategies, programmes and action plans were produced in the field of child welfare, including in relation to children with disabilities, juvenile justice, street children, protecting children against sexual exploitation and child labour. Whilst these policy documents are welcomed as a first step towards fundamental reform of the child welfare system, a number of very serious concerns and issues remain to be dealt with. The various strategies are not well supported with practical action plans for their implementation, including the identification of financial resources to back them up. As a result, there has so far been very little real change on the ground. Roles and responsibilities for implementation at a Government level are often unclear and there is a tendency for each strategy to appear in isolation from the others rather than as part of one, overall, coherent programme of reform. As the EU’s own Child Welfare Reform experts noted, different Ministries and Agencies develop their own policies without taking into account the impact which these could have on other bodies with similar responsibility for the delivery of services for children and families. The de-institutionalistion plan The 2003 RR noted that “…a plan to decrease by 10% the number of all children in specialised institutions in the period 2003–2005 was adopted in August 2003”’. This deinstitutionalisation plan was the main response of the Bulgarian Government towards the insertion of a requirement in the EU - Bulgaria Accession Partnership that there be a “systematic reduction” in the number of children in institutional care. It is the second time that targets have been set in Bulgaria for reducing the number of children in institutions: The first National Child Strategy (2000-2003) was agreed in 2000 in line with the negotiations for starting the Child Welfare Reform project, including an 8 million USD loan from the World Bank. The present National Child Strategy (2004-2006) (which was produced after the de-institutionalisation plan) was not based on any analysis of the implementation of the first strategy. As a result of this, the 2004-6 strategy simply repeats most of the objectives of the earlier strategy which was never made operational. It remains unclear how the plan is to be implemented in practice as no mechanisms or indicators are provided for monitoring its implementation. From the information available, it seems that progress in implementation – even for those measures defined as urgent and marked for completion in 2003 – has been very limited. Data collected by the SACP at the end of 2003 shows only a slight reduction in the total number of institutionalised children. The total number of infants aged 0-3 placed in Homes for Medical and Social Care in 2003 was 3155. This is actually higher than the figure for 2002 of 3141. The number of this type of institutions remains unchanged at 32. This is particularly

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

significant as all evidence shows that once children have entered the institutional system – in most cases, beginning with a Home for Medical and Social Care – they are likely to remain in institutional care for a long period of time, if not indefinitely. The increase in this category of institutionalised children is a failure which undermines all other efforts in this area. In relation to financing of de-institutionalisation the plan is inadequate. It states that almost all of the envisaged activities do not need dedicated extra finances and for those few which do, this will be financed ‘from the state budget’. This is a cause for concern as it does not seem to reflect financial and budgetary realities: financial support is needed in order to make a success of the development of alternatives to institutional care. Even if the state budget is sufficient, the question still remains of how existing finances can be re-directed to supporting this de-institutionalisation. Without a full evaluation of the costs involved, none of this work can really be properly planned. One example of how the lack of adequate funds and support from the government is hindering the development of alternatives to institutional care is in relation to foster care. The de-institutionalisation plan foresees that this will be developed nationally by January 2004. To date however there has been very little training in relation of social workers in this area and none of the panels approving foster carers has been trained. Statistics made available to date (until July 2004) show that 16 children have been fostered and 17 families have been approved as foster families. In addition to this, the current de-institutionalisation targets are not sufficiently ambitious. Every Child’s project, 'Children and Families', developed in partnership with Plovdiv and Haskovo municipalities, the State Agency for Child Protection (SACP) and the Ministries of Labour, Education and Health, has demonstrated that more can be done. This project achieved a reduction of some 25% in the number of children living in institutions as a result of reintegration strategies implemented by the two local Child Protection Departments (CPDs). Save the Children’s work on prevention of abandonment in Rousse provides another example of how more ambitious targets could be realistically set and met. The new approach used there lead to a reduction over 2 and a half years of 38% in the number of fully residential children at the Home for Medical and Social Care of Children (former “Mother and baby” home). At the same time, data collected by the SACP at the end of 2003 shows only a slight reduction in the total number of institutionalised children. The exclusion of Special Schools from the De-institutionalisation Plan The Bulgarian Government’s ‘Strategy and action plan for the protection of children’s rights 2000 –2003’ stated that the “number of children living in institutions as of the end of 1999 is 35,123”. The Bulgarian Government now claims there are 11,384 children in institutional care. Child rights NGOs in fact believe that there are still some 31,000 children living in institutions, the same estimate made by the European Commission in its 2003 Regular Report. These NGOs understand the new, lower, figure to be a manipulation of the statistics based on a very narrow definition of what an ‘institutionalised’ child is: the new total excludes all children who were not placed in institutional care on the basis of the Child Protection Act. This means that children placed in institutions under the Public Education Act (some 16,000 children) are no

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

longer counted. Children placed in institutions under the Law for combating anti-social behaviour of minors and juveniles (some 2,000) are also missed out. As a result of this, over 16,000 children who are placed in Special Schools under the Public Education Act are excluded from the de-institutionalisation plan. This is justified on the grounds that these children are not intended to be permanently resident in the schools. In practice, however the majority of these children do live in the schools for at least 5 days per week. They often cannot go back to their families even at weekends because of the remoteness of the institutions or the inability of poor parents to pay travel expenses. Most Special Schools are institutional in their essence: the children are permanently separated from their families, have reduced life opportunities and limited access to quality education. They should therefore also be a target of the deinstitutionalisation plan or should be covered by a dedicated de-institutionalisation plan of the Ministry of Education. Also omitted from the de-institutionalisation plan are those children in institutions for juvenile offenders (Social Pedagogic Boarding Schools and Correctional Boarding Schools). According to the SACP, in 2003 there were 2008 children living in these schools. In the case of Auxiliary Schools (one of the types of ‘specialised school’ discussed above), the Public Education Act states that children should be referred there after all other options for educating in the state or municipal schools have been exhausted and upon a written request submitted by the parents. However, in many cases these children do not appear to have any particular needs which would justify special education. The interdisciplinary diagnostic committees of these schools do not follow a common diagnostic methodology, do not work transparently and are not held accountable for their decisions. This results in the admittance of thousands of children who should instead be in the mainstream school system. In addition to this it is clear that many poor parents, particularly from the Roma community, have powerful economic incentives to send their children to these schools where the state pays for their schooling and provides free food. Legislative changes relating to the intake of children into specialised schools have been introduced but these measures are not yet accompanied by active attempts to reintegrate children from specialised schools into mainstream or vocational schools. In 2003 the government, supported by NGOs adopted a National Plan for integration of children with disabilities in the mainstream school system but failed to provide funding for its implementation in 2004, which blocked the start of the reforms for inclusive education. Administrative Structure of the Child Protection System The 2002 RR stated “enforcement and implementation of the Child Protection Act seems to be difficult due to the weak authority of the State Agency for Child Protection”. This issue was not taken up again in the 2003 RR although the role and strength of the SACP remains key to the success of the child welfare reform process. The SACP was given monitoring powers concerning child protection activities but there remain many concerns regarding its continuing weak authority. It is still financially reliant upon the Ministry of Labour and Social Policy, (MLSP) and whilst the SACP is charged with co-ordinating policy, it does not have the right to develop policy initiatives itself. There are parallel structures in the MLSP, duplicating to a considerable extent the work of the SACP. As a result there is considerable confusion as to which body in Bulgaria is

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October 2004

ultimately responsible for child welfare. For example, the responsibility to “undertake checks on complaints and referrals for breaches of the rights of the children” is given to both the Regional Directorate for Social Assistance (part of the structure of the Agency for Social Assistance (ASA) which is under the MLSP) and to the Directorate for Control on the rights of the Children (under the SACP). One fully independent body with oversight of all child welfare issues and a sole mandate to promote improved practice would be more effective and cost-efficient. As a result of the above confusion of roles at a central level, there is inevitably also confusion at a local level. CPDs receive methodological support from both the SACP and the ASA, via its local Directorates for Social Assistance. These local directorates prepare municipal strategies for child protection which the municipalities have to implement. And, some municipalities manage institutions for children. Despite this intended decentralisation of services management to municipal level, in fact the child protection system remains centralised, subordinated as it is to the ASA under the MLSP. Capacity in Child Protection Departments Research by Save the Children indicates that Bulgarian government data on child welfare reform often refers only to those locations involved in pilot projects funded by the World Bank and the EU - i.e. to only 20 of the 272 municipalities. To obtain a broader picture, Save the Children visited CPDs in non-pilot regions receiving no extra funding beyond that provided for in the state budget. In Belitza, one single social worker was found to be responsible for an area with 11,200 residents. In Troyan, two social workers and one legal adviser were responsible for 38 towns and villages with a total of 25,823 residents. In neither place did social workers have transport or even computers to maintain a basic database and CPD staff were often unclear about how to perform their work. In addition to being extremely under-resourced, they reported that their training consisted only in being given a copy of the CPA and the Rules for its implementation. No further training or funding was made available. This seems to be representative of the situation throughout Bulgaria. The SACP’s 2003 report states that CPD social workers need additional training and that the majority of CPDs do not have enough staff. This makes meeting accepted European standards for social work impossible – and undermines the entire child welfare reform. CPD staff were in a number of cases trained by NGOs. However there is a tendency for a high turnover of staff after parliamentary and local elections which erodes the newly built capacity. The Regional Directorates for Social Assistance, which are managing the local CPDs, also need greater capacity in order to provide the support needed by CPDs. As well as staffing levels, consideration needs to be given to the way in which CPDs are financed. The de-institutionalisation plan envisages aligning the number of social workers in CPDs with the number of children in institutions. It is not clear why this has been done – rather than linking the number of social workers with the overall child population in the municipality, given staff in CPDs have a range of responsibilities and are not working only with children in institutions. Such a linkage may lead to unwillingness on the part of those working in the CPDs to work towards reducing the number of children in institutions.

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October 2004

International Adoption The 2003 RR noted amendments to the Family Code. These establish the conditions under which International Adoption (‘inter-country’ adoption in international law) is to be allowed: only if all options for accommodation with relatives and family friends or for domestic adoption have been exhausted (when three Bulgarian candidates have declined to take the child within 6 months). The 2003 RR described the establishment of adoption boards and registers of children for adoption at regional level. It rightly identified the need for co-ordination of these registers with a national information system on the children who may be adopted, on adoptive parents and candidate adopters which was then being developed by the SACP. This national information system has still not been developed. In fact, what is needed most crucially is a unified national register for Bulgarian children who may be adopted and Bulgarians who wish to adopt. Currently, the Family Code does not provide for the setting of national register. However, the existence of such a register would increase the chances of a Bulgarian child being matched with Bulgarian parents and therefore allowing the child to remain in its country of origin. This would also reduce the reliance on international adoption. The 2003 RR also stated that, in line with the UN Convention of the Rights of the Child, Inter-Country Adoption should remain an exception. Research by Save the Children in late 2003 found that Bulgaria had an extremely high number of international adoptions making it one of the world’s highest ‘supplier’ countries. It is too soon to judge the extent to which recent changes in adoption legislation have had an impact on this. What is clear is that if sufficient resources are not devoted to the development of alternative care services, adoption – including international – will be used as a first rather than last resort. Close monitoring of implementation of the new legislation is therefore needed. And, more transparency in the international adoption system is crucial in order to avoid malpractice and exploitation of birth families, children and parents seeking to adopt. In particular, there is a need for regulation, at a central Government level, of official fees which can be levied in relation to international adoption. These should be widely disseminated to all interested parties. Trafficking of children Bulgaria is both a country of origin and of transit for trafficked children. A Stability Pact report cites the minimum number of Bulgarian trafficked victims between January 2000 and June 2003 as 352 of which a very high percentage of victims were minors – 48% in 2002. This same report notes that there is no centralized database or agreed upon methodology for collecting the number of trafficked minors cases in Bulgaria. Systematic data collection on trafficking is foreseen under the umbrella of the National Commission that should be established in 2004 – as of the time of writing, this Commission has still not been established. According to the Stability Pact report, most of these minors’ cases involve females who were trafficked for sexual exploitation. This is consistent with the findings of a US government study according to which victims of trafficking in 2002 were overwhelmingly women and girls trafficked for the purposes of forced prostitution. The average age for trafficked children for the purposes of sexual exploitation is 14-18 years. Trafficking for the purpose of international adoption is also recognised as a problem in Bulgaria. And, there have been a number of cases reported in the media of Bulgarian (un-born) babies who have been sold to foreign families (Greek, French and Italian). Traffickers identify the pregnant women and provide transport abroad where the women

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are placed in specially prepared homes for the birth. Until such time as international adoption practices in Bulgaria are both more transparent and better regulated, trafficking in babies for such illegal international adoption is likely to remain a problem. The toughest sanctions should also be taken against all of those operating in and supporting the trafficking networks.

People with Disabilities With regard to protection of the rights of people with disabilities the passing of the AntiDiscrimination Law at the end of 2003 and the submission to Parliament of draft laws for Integration of People with Disabilities, Equalisation of Opportunities for the Disabled, and Provision of Equal Opportunities for Persons with Disabilities have all been positive developments. Unfortunately, after the first reading hearings in the Parliament the third draft with the strongest focus on human rights and inclusion was rejected by MPs. In the beginning of September the second reading of the draft law was continued and finished within two days and on the 17th of September the Law on Integration of Disabled People was published in the State Gazette (official government bulletin). Disability social assessment without means-testing is now to be made effective as a requirement for disability entitlements. By-laws to this legislation are still to be drafted and it remains to be seen how the new system will work and whether discriminatory attitudes and practises towards disabled people will continue to be widespread in Bulgaria. The 2003 RR noted the National Strategy for Equal Opportunities for Disabled Persons that was adopted in June 2003. The Strategy contains measures to improve access to buildings and transport, education, employment, social services, legal protection and social and medical rehabilitation. The strategy was very welcome as an overall statement of intent but in many areas, considerable obstacles remain to full participation of people with disabilities. There is a failure to focus sufficiently on the practical ways in which policy in the field of disability is to be implemented. Experience with The Law on Local Elections and Requirements for Accessibility of the Election Polls for People with Physical Disabilities illustrates this problem: The passing of this law has been a step forward, recognising the right of people with disabilities to participate as active citizens in the democratic process. However, there was no information campaign on the change in legislation so many people with disabilities remain unaware of their rights and those who should ensure that these rights are protected remain unaware of their responsibilities. In practice, elections are still conducted in mainstream school premises with inaccessible entrances and no provision is made to help people with disabilities reach the polls. With regard to measures to improve access to employment, significant changes and amendments to the Employment Promotion Act were made in 2003. They were not however accompanied by provisions related to support services such as personal assistance or assistance at work and there continues to be a lack of clarity regarding enforcement procedures. Measures granting resources to employers are thought to be abused with grants to improve conditions for employees with disabilities being in fact spent on more general improvements in the workplace. Employers are even said to appoint “dead souls� (imaginary employees) to obtain grants. As yet the government has not published an assessment of the impact of these programmes. There is however a huge discrepancy between the data provided by different official sources as to the

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

October 2004

number of people with disabilities and no reliable data about their age, education or other characteristics is available. Enforcement regulations to the newly voted legislation in the employment section are still to be drafted. The 2003 RR states that the financial situation of people with disabilities has improved as a result of the allocation of a guaranteed minimum income, provided for in the amended Social Assistance Act in December 2002. Since the 1990s there has been a dramatic increase in the number of new disability pensions awarded and the total amount paid out in 2002 was BGN 314 million, some 1% of the Bulgarian GDP. This is to be welcomed. However, in many areas funding remains inadequate. To illustrate this statement it could be reminded that the government's adopted list of technical aids, which are clearly a precondition for inclusion in society of a person with disabilities, consists of only fourteen items which are outdated technically and given the inaccessible physical environment in the country do not contribute to the effective integration of the disabled. One of these, a leg prosthesis, is re-reimbursed at a rate of Euro 100 whereas for elsewhere in Europe – including the Czech Republic, Hungary and Poland - the rate of reimbursement is Euro 2000. The reimbursement rates obviously reflect the level of quality. Small and simple technical aids, such as adapted spoons for instance, are not reimbursed by the government and providers do not offer them at all. The only source of funds for adaptations of the physical environment remains the ‘Beautiful Bulgaria’ programme where BGN 5 million were designated. This was very welcome but there is need for a more sustainable financial plan which is an integral part of the state budget and not reliant upon external programmes. In other areas, funding appears to be misguided and mis-targetted, demonstrating a continuing lack of understanding of the real needs of people with disabilities. The most notable example of this is the so-called ‘Personal Assistance’ scheme – which in fact is more akin to a ‘family/home attendance’ scheme than ‘personal assistance’ as understood and practised elsewhere in Europe. Under this scheme, assistance in the home is provided to people with disabilities by unemployed carers. However, there is no assessment of the needs of the person with disabilities, including by them themselves. In general, the scheme appears to be serving the need to provide employment for the unemployed more than providing appropriate support for the service user. Institutional care for physically disabled people remains without a reasonable alternative in the community. People with Mental Disabilities The 2003 RR noted that a review of the situation in social care homes has been carried out by the Agency for Social Assistance and that as a result a programme has been formulated to ensure either the further rehabilitation or the closing down of social care homes by 2006. It correctly states that, although seven institutions have been closed, living conditions in the remaining psychiatric and social care homes continue to be inadequate, with scarce opportunities for rehabilitation and therapy and continued reports of ill-treatment. Since 2003 mental disabilities have received further attention but in daily life no significant change seems apparent. What is most key is not the shutting of homes but the opening of alternative services.

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NGO Alternative Report on Bulgaria’s Progress Towards EU Accession

3.

October 2004

MINORITY RIGHTS

Protection against Discrimination The 2003 Regular Report noted the adoption in September 2003 of a comprehensive Anti-Discrimination Law, envisaging the establishment of an independent Commission for Protection against Discrimination which is to appoint permanent panels to deal with cases of discrimination. Nine months after the law came into force, the Commission itself is still in the process of being established (the deadline set out in the law was the end of March 2004). There is a need for institutional measures and information campaigns to raise the awareness of service providers, as well as the general public, about the Protection from Discrimination Act.

The Roma Minority The 2003 Regular Report noted that the situation of the Roma minority had not changed significantly since that described the 2002 Regular Report. The grounds for this assertion are still valid after the 2003 report. The one-year Action Plan for the implementation of the Framework Programme for the Equal Integration of Roma in Bulgarian Society, announced in September 2003 almost five years after the programme was adopted, was the first government document to provide some, albeit limited, funding for some of the measures indicated in the Framework Programme. Unfortunately it failed to provide funding for basic priority aims, for example the desegregation of Roma schools and the integration of children in ethnically mixed education establishments. The plan also failed to put forward the necessary legislative changes in key areas of public life, which makes it difficult and in some cases impossible to implement the practical measures envisaged by the Programme. The Framework Programme itself is not backed up by reliable legal and institutional guarantees for its sustainable implementation. Education The 2003 Regular Report mentions the dramatically low levels of education of many Roma people and the fact that the geographical separation of many Roma communities in 'Roma neighbourhoods' has resulted in the existence of segregated schools. The Ministry of Education and Science (MES) issued instructions for the desegregation of Roma schools in two consecutive years (2002 and 2003), but these instructions have been almost totally ineffective during the last school year. Projects for the integration of Roma children in ethnically mixed schools are still only being implemented in a small number of localities on the initiatives of citizen organisations. In June 2004 the Ministry of Education and Science announced its Strategy for the Education and Integration of Children and Pupils from Ethnic Minorities for the period from 2004 to 2009. This was elaborated by a working group at the Ministry of Education and Science Advisory Council on issues of educational integration of children from minorities. Participants in the Council included representatives of a broad circle of citizen (including minority) organisations and made a great contribution to the development of this document with totally new visions, values, aims and objectives. The

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October 2004

Strategy is an innovative document for the Bulgarian education system and is based on international human/minority rights protection standards. The same working group also elaborated an Action Plan for the implementation of the strategy covering the same period. In the process of consultations between various ministries, the strategy encountered serious obstacles in the Foreign Ministry. Employees on a political level in this ministry made unsubstantiated demands for changes in its contents (including replacing the word “minorities” with a synonym), which would clearly deprive it of its meaning in terms of rights. As a result of interventions from various quarters, the changes finally imposed in the text of the strategy were not drastic. However, if the Action Plan, for its part, is subjected to the same kind of “consultations”, there is a real danger that the aforementioned ministry, or another, could further delay the implementation of the educational integration policy. The existing curricula, textbooks and teaching aids for the main school subjects, which still fail to stimulate intercultural dialogue and develop the identity of minority children, do not answer to the rights-based values, aims and objectives the Strategy for the Educational Integration of Children from Minorities. Most teachers and education administrators are unprepared and not trained to implement integration policy to promote, rather than diminish, ethnocultural diversity in schools. Universities still fail to provide future teachers with the relevant abilities to work in a multicultural school environment. The principles, aims and objectives of the strategy also require changes in many laws and sub-judicial acts in order to increase legal guarantees for its implementation. There is a lack of coordination between the growing number of institutional and organisational programmes relating to the educational integration of minority children. At the moment there is a lack of readiness for the implementation of ongoing monitoring and evaluation of the integration processes. The education components of municipal development strategies and plans are far removed from the values, priorities, aims and objectives of the Strategy for the Educational Integration of Minority Children, and schools are highly dependent on municipal policies. If urgent measures are not taken to resolve all of the above problems concurrently and to generate public support for the integration policy outlined, it will either not be implemented at all or will be transformed into a hybrid which will be of no use to anybody. With active participation by non-governmental organisations, MES drafted a Law for funding the educational integration of children and pupils from ethnic minorities, which will facilitate fundraising also from international programmes. It was submitted to Parliament in April 2004 and was discussed in the relevant commissions, but was not included in the list of laws urgently awaiting adoption. At a roundtable discussion initiated by non-governmental organisations on the 14th September and attended by Members of Parliament, categorical demands were made for the immediate adoption of this law. The Members of Parliament made specific commitments to submit the law without delay for debate in the plenary session. Non-governmental organisations are monitoring this process. Although the 2004/2005 school year is defined as the beginning of the educational integration strategy, as a result of the above it has started without the education system

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October 2004

being prepared for it in terms of funding, organisation and programmes. Due to this, thousands of Roma children have again been sent to segregated schools instead of ethnically mixed schools outside their neighbourhoods. The 2003 Regular Report notes the introduction in September 2002 of obligatory preschool preparation free of charge, one of the aims of which is to help the integration of minority children in the education system. The main expectations are for them to get a better command of the official language in a Bulgarian language environment. A serious omission of this preparation is that it fails to use the resources of the mother tongue of the children to assist in their adaptations. There is a total absence of ethnic Bulgarian teachers who have a command of minority languages and can work in a bilingual environment. There are very few Roma bilingual teachers. There is, however, some hope in the prospect that the first Roma students studying the new subject entitled Teaching with the Roma Language at Veliko Turnovo and Stara Zagora Universities will graduate in three years. The status of mother tongue teaching in Bulgarian schools is reduced to an alien appendage among school subjects because of the widespread misconception that providing more educational opportunities for mother tongue teaching would be an obstacle to the integration of minorities in society. This is why mother tongues are taught only as a foreign language and only for 4 hours a week. Accordingly there is a lack of education programmes in various subjects using the pupils’ mother tongue as a teaching medium. This opportunity is not permitted under existing legislation. The mainstream curriculum, with few exceptions, does not provide information on the history and culture of minorities and fails to recognise the contribution of minorities to the national history and culture. A new post of assistant teacher has been included in the list of nationally recognised professions and job characteristics have been elaborated for this post. Although the practice of introducing assistant teachers has been effective in other countries, after the first year of its existence in Bulgaria there are very contradictory assessments of its success and of the need for it. This is mainly due to the status assigned to these people and because of the lack of funding (finance was not made available despite the fact that in its one-year Action Plan the government allocated a sum 1,2 million Bulgarian levs for assistant teachers’ salaries). Health The 2003 Regular Report noted the substantially worse health status of the Roma minority compared to the majority population in the country and pointed out that Roma children are a special health-risk group. Members of Roma communities continue to have limited access to health care due to direct and indirect discrimination. The few health care establishments in neighbourhoods with predominantly Roma populations are understaffed, under-equipped and offer a lower quality service provision in comparison with those which serve members of the ethnic majority. Recently, the government decided to cover health contributions until the end of the year for underprivileged citizens registered at the labour office. All others who are not registered and are unable to pay their contributions (between 400000 and 2 million) will

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be excluded from the health insurance system from next year. This will have a very serious effect on the Roma community. There is still no information on the access of the Roma population to health care services and the availability of preventative health information. Elaboration of a National Health Strategy for the Roma Poplulation is still under way. This process has not been publicised at all, nor has any information about the deadline for its completion. Social Benefits System In the last few months some positive developments have been noted in the provision of social benefits. The Social Assistance Act currently stipulates that funding for social benefits be paid from the State budget. As a result, benefits are generally paid in good time, while previously they were paid through municipal budgets and there were frequent delays and non-payments. However, there are needs for further changes in the Social Assistance Act. It should specify in more detail the various groups it supports, one of which should be “ethnic minorities�, which in turn should be further subdivided. Citizen control of the implementation of the Act should also be ensured. Obstacles Roma face in receiving social benefits include: difficult access to state institutions; regulations which force claimants to choose one benefit at the expense of another (which is common practice applied to all citizens), depriving them of provision for basic needs; and lack of information about such programmes among the Roma minority community. The reason for which over 70% of needy citizens do not receive social benefits is the criteria for the selection of benefit recipients defined in the Social Assistance Act. These criteria should be changed in order to provide better protection for the rights of members vulnerable minority communities, comprising many members of minority groups. Roma non-governmental organisations and individuals should be able to play an active part in the allocation of social benefits. Employment The 2003 Regular Report mentions the national programme introduced by the Ministry of Labour and Social Policy (MLSP), 'From Social Assistance to Employment', which aims to offer employment to approximately 100,000 long-term unemployed people, mainly of Roma origin, in public works. These temporary employment programmes have not yet brought long term benefits. As a rule they offer people jobs for a few months as cleaners, gardeners or in other relatively low-skilled posts for minimal pay and with no inducement to improve their qualifications. The number of people who have passed through qualification courses (between 2000 and 3000) in the 70% unemployed Roma population is purely symbolic. The training component of this programme is insignificant in relation to the labour component and relates to a very small number of the illiterate people engaged in it. In addition, the contents of the programme are incomplete. As yet no effective measures have been taken to motivate people (especially young people) by providing adequate professional training or offering further employment to those who do a good job. The literacy and qualification training could become much more effective if Roma teachers are involved. Employees in Labour Offices and Social Services do not yet have qualifications to work with minority groups, even in municipalities with significant Roma populations. The number of Roma employees in these structures is negligible. There is a need to provide

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the Roma population with better access to information on available jobs and qualification courses by opening branch labour offices in Roma neighbourhoods, even if only for one day per week.

Other Minority Groups Romanies are not the only minority group whose rights are systematically infringed. There is widespread insensitivity among institutions, media and the public as a whole to instances of ethnic and religious intolerance and discrimination, which leads to a lack of adequate measures to overcome it. A case in point occurred on the 10 th August, when the leader of the Podkrepa trade union Konstantin Trenchev strongly incited inter-ethnic alienation with an overtly racist speech against Roma and with his proposal to create a vigilante “National Guard” to fight so-called “Roma crime” (including by means of weapons!). At the time only two institutions distanced themselves from him. The process of bringing domestic legislation into line with international minority rights protection standards is still not complete. The fragmentary and unequal implementation of these standards between one minority group and another leads to their differential protection from discrimination and unequal participation in public life. The ethnic minority status of some groups (the Macedonians and the Bulgarian-speaking Muslims/Pomaks) is not recognised. There is no common government integration policy based on human/minority rights protection standards. The model of what is currently referred to as minority integration fails to encourage public understanding of integration as a two-way process in which the majority as well as minorities must participate. There are no sustaniable results, inasmuch as institutional measures targeted at minorities are sporadic, lack mutual commitments and fail to generate public support. There is a lack of regular and reliable statistics on the social status of minorities which makes it difficult to prioritise needs and undertake adequate institutional measures (not a single state institution which carries out surveys and gathers statistics in the course of its activities includes ethnic markers).

Publicly owned electronic media In order to implement integration policy, as the government claims to strive for, there is a need for a positive public environment and the role of the media in this process is crucial. Bulgarian National Television, which is publicly owned and whose statutes oblige it to encourage cultural pluralism and inter-ethnic tolerance, regularly broadcasts particularly strong anti-Roma messages through one of its most popular programmes: Vsyaka Nedelya (“Every Sunday”). The state regulatory body, the Electronic Media Council, has still not imposed any of the sanctions provided for by law. The Electronic Media Council is also inactive with regard to many private television channels which violate the law in a similar manner. As a result of this uncritical institutional behaviour, the lack of standards for professional journalism and prejudices against minorities (especially against Roma), the media environment is flooded with hostile and often overtly racist speech. In this environment, the sporadic programmes on National Television (usually broadcast at off-peak times) which show the everyday life and traditions of minority communities have hardly any effect. There is still a yawning gap between the percentage of the minority population in the country and the percentage of

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minority representatives in the publicly owned electronic media. The latter is purely symbolic for some minorities and non-existent for others. There are no effective legal mechanisms and professional standards to guarantee the participation of minority journalists in the publicly-owned electronic media.

The National Council on Ethnic and Demographic Issues The powers of the specialised state structure on minority issues, the National Council on Ethnic and Demographic Issues at the Council of Ministers, are severely restricted. It is restricted to exercising advisory and coordination functions. Although its structures cover all administrative areas in most municipalities, their existence is a formality and they are weak and ineffective. It fails to include among its member organisations representatives of many minority groups, including those unrecognised by the state (Bulgarian-speaking Muslims/Pomaks and Macedonians). At the moment the status of the NCEDI is unclear. There are plans to replace it with another structure in the form of a directorate at the Council of Ministers, but at the moment there is no transparency concerning the process of its transformation.

4.

CIVIL AND POLITICAL RIGHTS

There were many valuable comments on these issues in the 2003 RR. However, some of the observations made distort the extent to which real progress has been made and others appear to be based on information that is incorrect.

Police Misconduct The 2003 RR noted that the situation as regards degrading treatment by the police had improved 'marginally' since the 2002 Report and recommended that steps taken by the government to address the situation should be further enhanced. In the period since the 2003 RR, police misconduct has continued to an extent far exceeding that in EU Member States, as has been reported by a number of domestic and international human rights monitors. The term 'degrading treatment' is perhaps inadequate - many incidents over the past year amount to police brutality and would more accurately be described as 'inhuman treatment' or even 'torture.' Torture is still not made a separate crime in Bulgaria as required by the UN Convention against Torture, nor has Bulgaria established universal jurisdiction to punish it. In ĐœĐ°y 2004 the UN Committee Against Torture reviewed the periodic report presented by the Bulgarian government and criticized the absence in domestic law of a comprehensive definition of torture. It also expressed concerns about the numerous allegations of torture and ill-treatment, which disproportionately affect Roma and about the lack of an independent system to investigate complaints of ill treatment. Only parts of the Bulgarian government have taken some steps to address the situation, notably the Ministry of the Interior and more specifically the National Police Directorate. However the attitude of other governmental institutions, in particular the Military Prosecutors Office, has not changed and as a result police brutality continues by and large to go unpunished. An amendment has been passed to the Ministry of Interior Act which authorises police use of firearms only against a person resisting arrest. However

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this does not add substantially to the regulation of the use of firearms by Bulgarian police, which continues to be in violation of international standards. At least two persons, both Roma, lost their life during 2004 after police officers used firearms against them.

Prison Conditions The 2003 RR correctly stated that conditions in Bulgarian prisons remained inadequate but noted some improvements, such as the construction of five new facilities in 2002. In fact this is not entirely correct. No new facilities were built: some older buildings were renovated and some additional, but not new, premises were supplied, several of which were not suitable for use as prisons. For example, the new facility opened at Kremikovtzi prison was formerly a school. Its conversion into a prison did not improve detention conditions, which have actually deteriorated at Kremikovtzi: prisoners now spend all day locked in overcrowded cells, which was not the case before. The 2003 RR also stated that many of the underground pre-trial detention facilities were closed. In fact at the time of the release of the EC RR only two such facilities had been closed. Subsequently the government closed several other pre-trial detention facilities, but not all that are underground. However the conditions in perhaps 90% of the remaining investigation facilities are still inhuman and degrading. In addition, the 2003 RR stated that a Ministry of Interior working group on human rights had adopted an action plan to implement the recommendations of the Council of Europe Committee for the Prevention of Torture. However, as a structure of the Ministry of Interior, this group cannot affect prisons or investigation detention facilities, which are institutions of the Ministry of Justice.

Juvenile Justice System During the period 2001-2004 a major consultative process took place on reform of the juvenile justice system, under the auspices of the Ministry of Justice and the UN. It resulted in the adoption of a National Strategy on Juvenile Justice. In 2002 the European Commission recommended amendments to the Law on ccombating the Antisocial Behaviour of Minors and Juveniles in order to satisfy their requirement for “improvement of the legal framework for placing juveniles in correctional institutions (VUI and SPI) towards ensuring their right to just process�. Amendments to this law were adopted in July 2004, although many experts in the field believe that in fact the law should have been repealed entirely. The amended Law, like the old one, treats children at risk and juvenile delinquents under the same legal provisions. This constitutes a major legislative flaw. These two distinct groups require separate support systems and therefore separate legislation. In addition, the amended Law fails to establish links with the Child Protection system. Although the law offers additional guarantees in the process of the imposition of disciplinary measures, it is still deficient in providing for the appropriate due process guarantees and establishes a procedure for adjudicating of the cases of the delinquent children that as a whole is of a lower standard than the penal procedure.

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Legal Aid The 2003 RR noted that whilst under the constitution legal aid is supposed to be available for everybody from the moment of detention or being charged, in practise there is no defence counsel in nearly 50% of criminal cases in the first instance. This situation remains largely unaltered. The share of criminal defendants receiving legal aid at the first instance has increased but the number of those who received it during the pre-trial stage remained unchanged. Research carried out during 2003 by the Bulgarian Helsinki Committee among prisoners charged after 1 September 2001 established that 49% of defendants who were subsequently sentenced to prison were not represented by a lawyer during their pre-trial proceedings. This is the same share prevailing before the amendments to the Criminal Procedure Code that were supposed to bring the situation into line with international standards. The Bulgarian law is also deficient in providing any free legal aid to poor people in the civil procedure.

Asylum The situation with regard to the right to asylum has worsened since the 2003 RR. A number of asylum seekers were expelled from Bulgaria back to their countries of origin while their asylum proceedings were still on-going, in clear violation of the law. In at least one case the refugee status of the person was cancelled, in violation of the Geneva Convention.

Freedom of Expression The 2003 RR stated that under the Radio and Television Law, broadcasters are independent and any opinion may be freely expressed. This is to overlook the control exercised by the Council of Electronic Media (CEM) which could be perceived as acting as a tool of the government. The RR 2003 failed to note that in early 2003, the government-appointed Director General of the Bulgarian Telegraph Agency undertook sweeping dismissals in the Agency, which led to public protests and widespread public debate on freedom of expression and the government's role in its protection and violation. As a result of the protests the Director resigned. The November 2003 suppression by the CEM of a TV operator provides another illustration of worsening developments in this field. More recently, in early 2004, the CEM dismissed the Director of the Bulgarian National TV, in violation of the law.

Religious Freedom This section of the 2003 RR fails to acknowledge or evaluate the negative human rights developments in this area. The Denominations Act is restrictive and discriminatory: it privileges one of the wings of the Bulgarian Orthodox Church, applies administrative compulsion to reunify it, and envisages a number of discriminatory measures against minority churches including a special regime of punishments for violation of the law. These deficiencies of the Denominations Act were exposed by a number of national and international organisations including the Council of Europe, the US government and Bulgarian and international NGOs during 2003. Most minority denominations had protested before and after the adoption of the Act, which was passed without consultation and against their will. In an unprecedented move in July 2004 the police, acting on orders by the Prosecutors Office, expelled the priests of the “alternative synod�

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of Bishop Inocenty from the churches they used for more than 12 years and transferred them to the synod that is officially recognized by the government. These included also churches that were built by the “alternative synod” supporters after the schism in the Bulgarian Orthodox Church.

5.

THE ADMINISTRATIVE CAPACITY OF THE STATE

The 2003 RR noted the ambitious objectives of the Strategy for the Modernisation of the State Administration of June 2002 to have a qualified and efficient Civil Service in place in the medium term. It also noted the October 2003 amendment to the Civil Service Law, which provides for compulsory competition for entrants to the Civil Service, the right to training for Civil Servants, and mechanisms for funding that training.

Staff Qualifications and de-centralisation Civil Servants and other public employees engaged in the provision and administration of public services need regular, comprehensive information regarding new legislation. Training in the new administrative systems required to perform their changing duties and on-going monitoring of compliance with the new systems are vital. Failure to invest in public servants has been one factor contributing to the failure to implement important reforms. One such example is the Framework Programme for the Equal Integration of Roma into Bulgarian Society, adopted in 1999. Five years on, most employees in institutions and departments at central, regional and municipal level remain unfamiliar with its provisions which have still not been introduced into their working practises. State administrative employees at both central and local levels and municipal administrations continue to lack knowledge and skills, and often even basic awareness, of rights-based policies and practises. Only a limited number of staff in Directorates for Social Assistance and Child Protection Departments have been fortunate enough to receive training from overseas development agencies and NGOs. All officials should be required to demonstrate their competence and understanding of human/minority rights in order to be employed or promoted in these institutions. This requirement should feature in their job descriptions and be regulated by means of amendments and riders in the relevant legislation and sub-judicial acts. In the absence of a functioning system for further qualification of public employees, and any way of monitoring the results of their work, it is unlikely that the full and effective implementation by 2007 of the Action Plan for the Implementation of the Framework Programme for the Integration of Roma, the Plan for Reducing the Number of Children in Specialised Institutions, the National Strategy on Equal Opportunities for the Disabled and associated draft legislation and other important legislative and policy reforms can take place. There is also insufficient consultation between Government at a central level and those charged with delivering services at a local level. There appears to be no real national strategy making, with the full participation of municipalities in the policy-making process – rather there is just centralised strategy making. Implementation at a local level of policies is clearly compromised when they are perceived as being imposed from a central level.

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Education Modernisation Project Modernisation of the education system is key to bringing lasting, positive change in the social sector, including the inclusion of children with special needs and minority groups who are currently excluded from the mainstream school system. The Education Modernisation Project (EMP) was financed by a loan from the World Bank for US$60 million, divided in three phases for nine years. The first phase was for US$14.39 million. After three successive unsatisfactory evaluations by the World Bank, in December 2003 the loan was frozen by mutual agreement. The Project for Monitoring and Evaluation of Activities under the EMP was executed by the Association for Social Investigations and Applied Research Practices. Their conclusions identified a lack of capacity and willingness to implement the reforms as the reasons for the project’s failure. It was discovered that the MES working group had begun the project by developing normative and working documentation which significantly altered the initial concept of the project. The purpose of these project changes seemed to be to avoid actual reform – including important changes related to the responsibilities of the MES itself for implementing reform. Components that would have developed a uniform education management information system were removed whilst management units intended to guarantee the steady implementation of reform were not established. The project had always stipulated that the success of its reform depended upon its beneficiaries being fully familiar and fully engaged with its purpose, yet the EMP was never publicised. One of the key components, the Education Management Information System, was not started at all. Funds were spent without direct relation to the purposes of the reform as the MES had no programme for reform. This illustrates the extent to which significant and lasting change is not possible, despite huge funds being made available, if there is not real commitment to change within Government.

6.

THE ROLE OF NGOS

The 2003 RR noted the participation of NGOs in the preparatory legislative process. It cited public-private consultative bodies such as the National Council for Rehabilitation and Social Integration, the Council for Social Assistance and the National Council for Child Protection. Whilst the existence of such bodies is to be welcomed in principle, in practice the extent to which NGOs are really encouraged to contribute to policy developments through these bodies is very limited. There is a need for greater transparency in the relationship between NGOs and Government to ensure that there is wide and genuine consultation. Draft legislative texts are frequently provided to NGOs at a very late stage in their discussion making any serious, comprehensive analysis of them almost impossible. In some cases – such as with the Denominations Act – there has been no NGO consultation at all. To date there is not a single example of a policy initiative that originated with the National Council for Rehabilitation and Social Integration, nor with the Public Council within the Civil Society Commission in Parliament.

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There are also structural limitations in the ways in which these consultative organs are set up. In the case of the National Council for Rehabilitation and Social Integration, participation in this body by disability NGOs is restricted by requirements as to membership and number of registered branches around the country. No weight is afforded to NGO activities, achievements or community influence and no assessment is made of their real expertise. The National Council for Child Protection is only a consultative body to the State Agency for Child Protection, which in turn can only submit proposals to the MLSP. It is the MLSP alone which decides whether or not to submit these proposals to the Council of Ministers – which means that in practice, NGO involvement is very indirect. Given the considerable experience which the Bulgarian NGO community has of working with disadvantaged groups, and the extensive international resource network to which they have access, it is unfortunate that more use is not made of their expertise. There is also a need to introduce and regulate citizen participation in monitoring the implementation of legislation and in evaluating the results. The establishment of public advisory councils in ministries and municipal administrations, in which representatives of NGOs could take part in developing institutional policies, could greatly assist in monitoring and evaluating progress. NGOs could also play a greater role in sensitising the public to issues concerning the rights of vulnerable groups. Such enhanced consultation of NGOs is vital if they are to feel greater ownership of the policies developed. This in turn is crucial given the Government’s stated aim that in many sectors, NGOs themselves will become social service providers. At the moment, the number of NGOs which are able to work in this way remains relatively limited, particularly in smaller towns and more rural areas. Working in genuine partnership with NGOs will be to the benefit of the NGOs and the Government, increasing the capacity of both and ultimately contributing to the more successful design and implementation of policies and programmes.

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7.

October 2004

CONTACTS:

Laura Parker Programme Director for Bulgaria Save the Children UK 38 Ivan Vazov Str. 1000 Sofia BULGARIA Tel: + 359 2 9874237 Fax:+ 359 2 9881476 Email: l.parker@savethechildrenbg.org www.savethechildrenbg.org

Krasimir Kanev Chairperson Bulgarian Helsinki Committee 7 Varbitsa Street 1504 Sofia BULGARIA Tel: + 3592 943 4876, Fax:+3592 944 0670 E-mail: krassimir@bghelsinki.org www.bghelsinki.org

Kalina Bozeva Chairperson Inter Ethnic Initiative for Human Rights 9A Graf Ignatiev Str. 1000 Sofia BULGARIA Tel: + 359 2 9801716 Fax:+ 359 2 9800108 Email:bozeva@ inter-ethnic.org www.inter-ethnic.org

Kapka Panayotova Executive Director Centre for Independent Living 2 Gurguliat Str. 1000 Sofia BULGARIA Tel: + 359 2 9898857 Fax:+ 359 2 9805839 Email:cil@ cil-bg.org www.cil-bg.org

Ivanka Ganozova Executive Director EveryChild EveryChild Bulgaria 22 Juri Venelin Str. Sofia 1000 BULGARIA Tel/Fax: + 359 2/ 9807058, 9813881 E-mail: everychild_vg@evrotur.net Website: www.everychild.org.uk

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Alternative NGO Report on Bulgaria's Progress Towards Accession to the EU, 2004