DG Enlargement Draft Guidelines for EU support to media freedom and media integrity in enlargement countries, 2014-2020 1. Media Freedom and Media Integrity in the Enlargement Region Freedom of expression is a fundamental right safeguarded by international law, including the European Convention on Human Rights, and forms an integral part of the functioning of a pluralistic democracy. According to the Press Freedom Index 2013 (Reporters Without Borders), the picture of media freedoms in the Western Balkan countries and Turkey aspiring towards EU membership is diverse1. Media politicisation and media clientelism are at the core of the most serious problems faced by the media. In the Western Balkans, the economic crisis combined with the global growing public preference for free internet-based media have led to a reduction of resources for established media and further increased the pressure on professional journalism. And when job opportunities decline, journalists as a community have proved to be weak in its capacity to further develop and protect common professional and labour standards. The independence of regulatory authorities is constantly challenged and not sufficiently supported by law. The judiciary by far too often is used to silence critical media. The Public Service Broadcasters are still struggling to obtain editorial independence, financial sustainability and accountability in their service towards citizens. The substantial investment from the international community to strengthen independent media in the post-conflict Western Balkan countries has gradually been withdrawn. This trend is not likely to reverse. In the media landscape only a few independent media outlets have managed to survive the transition and the current economic crisis. Some have been absorbed by the clientelistic system whereas others are surviving with meagre resources. The existing not-for-profit media NGOs are still largely dependent on international donors to sustain their missions2. 1 Serbia shows some progress and is the highest ranked country in the Western Balkans in place 63, advance of 17 places compared to last year’s Index. FYRoM on the other hand dropped full 22 places from 94th last year to 116th in the 2013 Index. Of the other countries of the Western Balkans, Bosnia and Herzegovina is 68th, Albania 102nd, and Montenegro is ranked 113th. Kosovo* was considered separately and is ranked 85th. Turkey, where severe limitations to freedom of expression and press freedom prevails, shows further decline in the Index and places itself in place 154 out of the 179 countries ranked. The overall low ratings were due to judicial pressure on the media, the lacking or inadequate legislation, numerous instances of intimidation of journalists, and lack of proper access to public information. * This designation is without prejudice to positions on status, and is in line with UNSCR 1244 and the ICJ Opinion on the Kosovo Declaration of Independence. 2 See detailed country by country assessments of freedom expression and media in the Enlargement Package 2013: http://ec.europa.eu/enlargement/countries/strategy-and-progress-report/index_en.htm Draft 23/10/2013 1 2. The Enlargement Agenda for Media Freedom and Media Integrity It is essential that the enlargement countries guarantee open and pluralistic media landscapes which allow for a culture of critical and independent journalism. Without the presence of a fully free media, citizens in the enlargement countries are denied the right to balanced, factual and reliable information without exposure to bias and propaganda. However the present media situation poses risks to the full transition towards stable transparent democracies and effective institutions3. Hence it is an integrated part of the Copenhagen political criteria for accession to the European Union. The EU accession process is a unique opportunity to encourage far reaching reforms in EU candidate and potential candidate countries. Endeavours to improve transparency, anti-corruption efforts and demand for accountable and transparent politics can only succeed if independent media are allowed access to information and have the capacity to process information and make it available to the public. Given the prominence of the challenge, the EU has decided to use the leverage of accession negotiations, where the issues related to the enabling environment for media freedom are being integrated in the comprehensive action plans under Chapter 23: Judiciary and Fundamental Rights. Implementation of the plan would form conditionality and determine the pace of the entire negotiation process. For the countries, not yet negotiating Chapter 23, a similar/comparable mechanism will be put in place. The regular Progress Reports and annual Enlargement Strategy and the conclusions of the Speak Up2 conference (20 June, 2013)4 brought to the fore a set of priority issues relevant for putting in place robust conditions for independent media and to be pursued in the enlargement process and in the perspective of the Instrument for Preaccession Assistance (IPA) II: The governments need to step up efforts and show a solid track record on investigations on violence and intimidation against journalists. Rules for transparency of media ownership need to be put in place in line with European standards, as well as checks against informal economic pressures on media. Transparent rules and procedures for the use of public funds in media (e.g. in form of the so called “government advertisement”) adopted and implemented to mitigate clientelistic support to pro-government media and unfair competition within the media market. Judicial capacities to protect freedom of expression and press freedom in accordance with European standards need to be developed. 3 As example, Transparency International’s anti-corruption monitoring in the countries shows that progress has been uneven and several countries continue to grapple with systemic corruption in their public institutions. The Corruption Perceptions Index in 2011 found that accession countries in the Western Balkans and Turkey all scored under 4 (0 being highly corrupt, and 10 very clean). 4 http://ec.europa.eu/enlargement/policy/policy-highlights/media-freedom/index_en.htm Draft 23/10/2013 2 Public Service Media remit meant to guarantee content pluralism and matching reform strategies to be developed, agreed and implemented to ensure transition towards an independent, accountable and sustainable public service broadcasting system. 3. EU Support A country wishing to join the EU needs to have an appropriate regulatory environment to ensure the exercising of freedom of expression and the presence of a free media. In order for independent media to be capable to fulfil their role they need to be able to access and impart information without interference by public authorities or business circles. Even though there is a little of the EU level regulation for the media sector, the European Commission is fully mandated by the Copenhagen political criteria to thoroughly assess the media situation in the countries aspiring the EU accession and to demand correction of the identified shortcomings. Therefore the preferred way is that Government Media strategies and laws are designed in line with the Council of Europe standards5. The Commission is committed to support meeting the objective of achieving sustainable conditions for freedom of expression and media. At the same time, the Commission recognises that genuine professional and independent media cannot be created exclusively with political support and financial assistance from the outside. With limited resource available it is important that the identified priorities are taken up and founded in national and regional strategies and owned and developed by media sector stakeholders themselves. Moreover, the development of strategies and laws shall take place with proper consultation with the media community and civil society, including in particular journalist professional organisations, thinktanks and human rights organisations. Equally, it is crucial to understand that the identified tasks are not to be accomplished by ad hoc or insulated assistance actions. The nature of the issues (e.g. establishing a functioning self-regulation, changing the mind-set of judiciary, etc.) requires a long term engagement. (Once developed the assistance programmes might stretch up to 5 years). In this regard the European Commission is looking forward to cooperate with partners from international institutions as CoE, OSCE, UNESCO, other European and regional organisations while building on their respective mandates, strengths and expertise in the media area. A regional approach to support will be explored to create synergies and enhance efficiency and allow for a broader outlook on the issues and practices. To ensure effectiveness of the above assistance approach, the Commission will continue to politically raise the issues of relevance to freedom expression and media with the governments in the Enlargement countries (notably, in the context accession negotiations, where available), and it will underline their importance for EU membership 5 These standards – conventions, recommendations, declarations, guidelines, etc. – are based on Article 10 of the European Convention on Human Rights and the relevant case-law of the European Court of Human Rights. Draft 23/10/2013 3 3.1 Enabling Environment and Resulting Responsibilities of Main Actors The task of putting in place an enabling regulatory environment for free, professional and impartial media stretches far beyond of adopting a few principal provisions in constitutions or comparable law. Freedom of Expression is a fundamental right, but at the same time it is pivotal for functioning of democracy and good governance in the given country. Moreover, implementation of this freedom is largely embedded in the economics, media and advertisement markets. This explains the comprehensive range of challenges to be addressed by an accession country and the multitude of the responsible actors within that country. The national Parliaments bear the ultimate responsibility for the state of democracy in their countries. Therefore support should be provided to them enabling to regularly assess media situation in their respective states in a way that would be objective and comparable, that would allow to act upon the shortcomings of national media legislations and practices, and to take appropriate measures in order to amend those defects. Such analyses could be done compared to the set of principles determined with the Resolution 1636 of the Parliamentary Assembly of the Council of Europe on indicators for media in a democracy6. The modalities of support would include parliamentary twinning and peer reviews and should encourage dialogue with civil society. It is the responsibility of the state to protect journalists from physical threats or assaults due to the work they do. In parallel with raising this point with national authorities, the EC will explore with partners options for accompanying measures to contribute to legal and physical protection of journalists. It is still very common in some accession countries that politicians and state officials attempt to silence media criticism by suing journalists. By fare too often the judiciary – deliberately or instinctively - take the side of the state and its officials while ruling on these cases. Continued work on development of judicial procedures and practices that protects freedom of expression and media in line with the Article 10 of the European Convention on Human Rights and applicable case law will be encouraged and supported. This could include updating and improving the capacity of the national judicial training programmes in the countries, support to law schools and faculties to improve curriculum related to freedom of expression and the understanding of case law practices. The regulatory authorities in the broadcasting sector are pivotal to ensure fair business practices, protect media and content pluralism by enforcing the rules for transparency of financing and preventing excessive ownership concentration or its close affiliation with political interests. Though in many cases the legislation in place by itself doesn’t prevent risks to independence and professionalism of regulators. The main attention needs to be paid and support given to strengthening of independence and professionalism of regulatory bodies and to creating a credible enforcement track record by them. With the share of commercial advertisements having shrunk considerably, the government publicity campaigns – the so called “government advertisement” becomes a powerful leverage to influence 6 http://assembly.coe.int/mainf.asp?link=/documents/adoptedtext/ta08/eres1636.htm Draft 23/10/2013 4 contents of reporting. Putting in place proper (public procurement alike) rule and enforcing them is a priority. Transparency in implementation is must. There should be a media community-government dialogue on what are the necessary checks to be put in place in order to reduce informal business influence on reporting. The national Public Service Media (unlike commercial media) are created by law or a similar act and receive public funding for their operation. However they continue to face challenges in defining the public service remit and public interest, protecting its independence, building the necessary demand for services the public is willing to pay for and manage the switch from analogue to digital broadcasting. These challenges can only be addressed if there is a political will and ability to develop and implement a strategy with a broad public support and with the necessary means allocated for it to succeed. The EC will support such strategic initiatives through both politically encouraging the governments to continue with PSB reform and technical assistance and mentoring programmes as envisaged in its Memorandum of Understanding with the EBU. 3.2 Advancing Media to a Modern Level of Internal Governance The wide spread clientelism in media, frequent deviation from professional and ethical standards in reporting, diminishing of the share of serious analytical reporting, shrinking content pluralism have led to a significant drop in public’s confidence in printed and broadcasting media. It should be also noted that deviation from transparency and honest business principles exposes media outlets to additional pressures in the form of risks of the selective justice and impairs independent reporting. To this end, initiatives to restore good governance at the level of individual media outlets should be encouraged and supported. First and foremost it would mean introducing transparency regarding the ownership, cooperate governance and financing in media outlets. Adequate contractual labour relations are of importance to ensure independent reporting. In-house editorial codes and an honest, transparent and efficient mechanism to address complaint’s from readership or viewership is an important factor for public’s trust in the given media outlet. Investing in education of journalists (also in applying professional standards) forms a part of good governance. In the context of regaining public’ trust in traditional, off-line media, it is important that the enlargement countries develop proper systems for basic and continuous training and education of journalists and journalist students on professional standards, freedom of expression and media integrity. Ad hoc training should be avoided and the needs and opportunities for support to journalist schools to develop curriculums also related to on-line media should be explored. Special effort should be made to promote the development of quality investigative journalism, e.g. through substantial training, support and mentoring schemes, and through the reinforcement of networks to enable a closer cooperation between investigative journalists and Civil Society Organisations. Investigative journalism should be fostered within the public service media, as well as in the commercial media and independent production houses. As online media are gaining grounds, Draft 23/10/2013 5 the challenge on application of media standards in the digital environment and opportunities and threats to freedom of expression will remain a theme throughout the period. The EC will make it possible for stakeholders in the enlargement countries to engage in dialogue with key institutions and actors in the EU on internet media through e.g the People to People (P2P) Programme. 3.3 Increasing Capacity and Representativeness of Journalist Professional Organisations Mature and credible journalist professional organisations are a key driver in advancing ethical codes and self-regulation, labour standards and enabling media legislation. Currently the civic segment of the journalist community (as an inevitable precondition for protecting professional standards and labour rights) is weak and organised interests are often disjointed without a long-term common vision. Ethical editorial codes and mechanisms for voluntary self-regulation and adherence to principles of good governance will get their grounds if media owners, journalist organisations and other key stakeholders are willing to transcend their divides and engage in a dialogue to reach agreement on common rules, as well as their readiness to subject themselves to these common rules. Efforts to establish such dialogues should be supported both politically and by provision of concrete advice when windows of opportunities emerge. Poor labour relations at media outlets (including absence of proper work contracts) is a powerful factor of self-censorship. Again, fragmentation of the journalist community is the obstacle to solidarity when common interests – labour rights are at stake. To this end, initiatives to develop capacity of journalist associations and unions to achieve the above strategic objectives need to be supported – among other forms - through collaboration with EU based journalist associations. Media Partnership Program will be put in place by using the Civil Society Facility7. The partnerships shall improve the quality and broaden the dialogue within the media community and between the media community and governments. By bringing together representatives from different organisations in the Western Balkans, Turkey and EU, the multibeneficiary support will enable common lessons learned, synergies and identify the added value and complementarity of the Media Partnership Programme to on-going efforts at the national and regional levels. The Media Partnership approach can be replicated at the national levels according to the particular issues to be addressed there. It will make it possible for organisations committed to improved media freedom and standards to perform activities based on a joint strategy and agreed programme of activities. 7 CSF – a financial assistance programme within IPA, meant to raise capacities of civil society organisations in the Enlargement countries: http://ec.europa.eu/enlargement/tenders/support-for-civil-society/civil-societyfacility/index_en.htm Draft 23/10/2013 6 Draft 23/10/2013 7 ANNEX A: DRAFT RESULTS FRAMEWORK The proposed results framework has been developed in line with the principles and objectives set out in the draft guidelines for EU support to media freedom and integrity 2014-2020. It has been conceived as a framework for the enlargement region as a whole and will provide the basis for a tailor-made approach at national level in accordance with the country context. Indicators are to be defined in consultation with media community stakeholders and relevant international organisations and other stakeholders at a brainstorming event in November 2013. The same are to be re-fined further considering them under the operational / easy-to-estimate point of view. Objective Result Indicator Enabling environment and resulting responsibilities of main actors 1. An enabling legal 1.1. Parliaments (and 1.1.a. Periodic Yearly and policy governments) in Enlargement assessments of existing media environment for the countries conduct periodic legislation and other legislation exercising rights of assessments of the state of affecting media and factors freedom of media freedom, measuring influencing freedom of expression and media national laws and practice expression conducted against a range of basic and media integrity. 1.1.b. Number of proposals (e.g. principles on the “quality of policy approaches, draft laws) law” stated in ECtHR case-law made and implemented as a and the indicators listed in the Council of Europe PA Resolution result of the above assessments 1636 (2008). Proposals to 1.1.c. Extent to which Journalist address the shortcomings are professional organisations and put forward. media interested NGOs are involved in preparing the 1.1.1 Parliaments (and parliaments’ assessments and governments) in Enlargement follow-up proposals (including countries adopts legislation in line with basic principles on the shadow assessments). “quality of law” stated in ECtHR case-law and the indicators listed in the Council of Europe PA Resolution 1636 (2008). Proposals to address the shortcomings are put forward. Draft 23/10/2013 1.1.d. Media is consulted in drafting media-related legislation in a transparent manner 1.1.e. Legislation provides for independent and professional operation of regulatory authorities MoV/Comment Independent assessment Monitoring of parliamentary committees related to media Independent survey of journalists/ngos Parliamentary records/report Online consultation websites? Independent assessment (media acts as watchdog for legislative processes/corruption)T BD 8 1.2. Judiciary exercises authority acts in conformity with article 10 of the European Convention on Human Rights and applicable case law. 1.2.a. Judicial training national curricula regularly updated on media freedom case law and standards developed and regularly updated. TBD 1.2.b. Increase in numbers of judicial staff trained in applying ECtHR case law on freedom of expression and legislation affecting media freedom. 1.2.c. Number of verdicts in cases related to media coherent with European Court of Human Rights case law 1.2.d Dynamics in numbers of court cases (acquitted cases, convictions, levels of awarded damages, etc.) where charges are pushed by politicians public officials on grounds of media criticism (defamation and similar other laws). 1.2.e Relevant case law from ECtHR in application of article 10 translated and published in local languages by judicial institutions 1.3. State institutions and public authorities take positive actions to defend ensure and promote media pluralism and their independence. 1.3.a. Journalists Assessments of access to information: rules and their implementation show that public by authorities are open and transparent .persisting legal restrictions on grounds of privacy and national security 1.3.b. Number of cases of physical attack, threats, law suits and other forms of intimidation against media decreases. Such Journalists and media organisations report adequate protection against physical threats and attacks and that such cases are timely dealt with Draft 23/10/2013 1.3.a. Survey 1.3.b. survey TBD 9 by law enforcement and judiciary in a timely manner. 1.3.c. Regulatory authorities of the broadcasting sector operate without political or other interference in a transparent and effective manner. The legislation provides for independent and professional operation of regulatory authorities of the broadcasting sector without political or other interference and in a transparent and effect1.3.d. Regulators provide transparent, credible and accessible records on media ownership and economic performance/financial statement are available; 1.3.d.1 Legislation against media monopolies and dominant market positions – properly enforced (track-record) 1.3.e. “State advertising” and any other direct or indirect use of public money in media handled in accordance with good governance to guarantee fairness, neutrality and equal treatment (rules are in place and enforced by the competition authority or comparable).Transparency in dispatching adds by big stateowned companies. 1.3.f. Transparency in dispatching ads by big stateowned companies. Volume and share of State advertising per media outlet is made public. 1.3.g. Public policies take into account sector analysis, inluding independent and verified audience research Viewers’/readers’ monitoring Draft 23/10/2013 10 (rates) carried out and published. 1.3.h. Regulatory bodies perform periodic sector analysis to prevent and disclose checks are in place to alleviate informaleconomic pressures on independent reporting (e.g. by adds agencies). 1.3.i. Other actions undertaken by authorities and aimed at promoting free expression and media pluralism. 1.3.j. Digitalisation process carried out in transparent way that ensures media plurality. 1.3.k. Internet remains free. 1.3.l Privatisation of stateowned media carried out in transparent manner with respect for fair competition 1.3.m Public authorities promote media literacy 1.3.n Public authorities develop strategies for the support of new/online, local and alternative media 1.4. Public Service Media / Broadcasting – ensure content pluralism in media environment. (independence – financial sustainability – transparency and fair election of board – public involved in programming-professional standards) 1.4.a. Assessment of the Public Service Media remits definition law (as preceded by broad public consultation), including standards on: transparency, election and composition of board & council, involvement of public in programming, complaint mechanisms, financial independence and sustainability, etc. TBD 1.4.b. Law provides for editorial independence and against politicisation of PSB. Draft 23/10/2013 11 1.4.c. Assessment of the implementation of the law (see 1.4a) independence and professionalism of governance structures of Public Service Media (track-record). 1.4.d. Implementation of long term reform of Public Broadcasters guided by comprehensive and budgeted strategies (matching the PS remit). 1.4.e. Sustainability and autonomy of PSB financing mechanism. 1.4.f. PSB subscribe to accountability by publishing annual reports (including financial) according to Public Service Remit as provided for in law and annual work plans. 1.4.g. Effective mechanism in place to deal with viewers’ complaints. 1.4.h. measuring dynamics of public’s trust in PSB. 1.4.i. level of completion of the digitalisation efforts Advancing media to a modern level of internal governance 2. Improved 2.1. Media outlets adhere to standards and principles of good governance. accountability in media sector. Growing public’s confidence in media. Financial sustainability of media outlets. Indicator: audience measurement for publications/broadcas ts with investigative Draft 23/10/2013 2.1.a. The share of media outlets that provide open access to key data (balance sheets and ownership structure) about corporate governance and finances. Register of media and register of companies The % of companies that publish sources of finances (incl. state aid and state (advertising) / market share The body for protection of competition The level to which the Law CSOs/NGOs and 12 content 2.2. Media outlets subscribe to and implement adequate labour standards. Adopting minimum wage rate / editorial independence / journalist independence / signing collective agreements Issue of free lancers 2.3. Self-enforcement of ethical norms and professional standards. 2.4. Structures strengthened for basic and continuous training and education of Journalists and journalist students with Draft 23/10/2013 (related to the transparency in relation to the ownership) has been implemented regulatory bodies 2.2.a. increased share of journalists reporting adequate working contracts with sufficient social protection. TBD The number of signed collective agreements The number of media outlets with internal code of conduct The level to which journalists say that they can do their job independently Survey by journalist associations/civil society media organisations 2.3.a. Share of media outlets with developed in-house codes and effective mechanisms to deal with readers/viewers complaints (e.g. ombudsman, readers editor). TBD The % of media outlet with developed, published and implemented internal code of conduct (in accordance with IFJ – International Federation of Journalists). Survey of journalists The content review of the media outlets Review conducted by professional agencies/CSO/press council/watchdog media monitoring groups. 2.4.a. Number of curriculums for journalist colleges/schools developed and implemented incorporating ethical codes and TBD 13 professional standards, freedom of expression and media integrity. Qualitative and trustworthy investigative journalism available to the citizens. standards. 2.4.b. number of internships increased and professional journalists and publicists as resource persons in training programmes. The level of professionalism in the sector The breaches (breech) in the professional conduct Recognition of quality journalism (prizes) Media monitoring groups/watchdog CSOs Journalist professional organisations EU/award system established in countries by Association of journalists Share of quality investigative journalism in local on- and offline media. Share of outlets’ (including PSM) budget used to investigative journalism. 2.5. Media outlets promote professional training (including on professional ethics). Increased managerial capacities in media outlets 2.6. Regaining audience’s confidence. Draft 23/10/2013 The number of media outlets with implementing business plans towards financial survival in a changing market. Market share/financial reports 2.6.a. Growing audience ratings for outlets embarking upon improved governance. 14 3. Qualitative and trustworthy investigative journalism available to citizens . 3.1. Improved conditions for quality investigative journalism (see also: 1.3.b; 4.5.a; 2.4.b). 3.1.a. increased cooperation between media organisations, media outlets and CSOs benefiting investigative journalists. (Objective 4) TBD 3.1.b. Share of quality investigative journalism in local on- and off-line media. 3.1.c. public recognitions of quality investigative journalism (audience measurement for publications/broadcasts with investigative content). 3.1.d. Share of outlets’ (including PSM) budget dedicated to investigative journalism. Increasing capacity and representativeness of journalist professional organisations 4. Members’ 4.1. Regular dialogue within the 4.1.1. Frequency Regularity and organisations (Media media community established on productiveness of meetings organisations, press freedom and integrity conducted (e.g. leading to joint journalist profess ( issues. Broad platforms conclusions and actions). organisations (including: NGOs, think-tanks - Number of joint initiatives (associations and ,journalists, editors, andowners, among journalists on national unions), CSOs dealing members organsition, media civil and regional level conducted with medial issues) society organisations) formed. - Active fund programme for develop building the capacities of professionally to member organisations enabled influence governments, public service broadcasts, media outlets. 4.2. Media 4.2. Media and journalist Representative organisations/journalists organisations engage into media and journalist associations are acting based on informed dialogue with professional long-term vision and strategies authorities. Positive dynamics organisations capable to achieve impact. in membership figures. of taking - The public is more aware for responsibility of media freedom issues sector relevant issues - Number of advocacy actions in dialogue with are organised authorities as well as - Number of joint policies and providing services to actions by member their members. organisation on national level are organized Draft 23/10/2013 The surveys will increase the engagement of stakeholders and will assist in determining the subject 15 - Number of members who benefits free legal aid - Number of services and their quality from member organisations offered to members is increased and improved - Number of members is increased to member organisations 4.3. Media organisations monitor and evaluate the results and impact of their own work. 4.3.a. Media organisations that monitor and evaluate their projects and programmes using baselines and quality indicators. 4.4. Platforms (journalist professional organisations, NGOs, media owners and editors) set up and actively to promote professional standards and ethics. 4.4.a. Presence of selfregulatory bodies with relevant representation from the media community, effectiveness of the agreed rules. TBD 4.4.b. Dynamics of financial contributions from media community and media owners to common self- regulatory body/-ies (e.g. a Press Council), indicating respect of the commonly agreed rules institutional sustainability. 4.4.c. Self-regulatory body available for advice to judiciary. 4.5. Labour standards developed and adhered to. 4.5.a. increased share of journalists reporting adequate working contracts with sufficient social protection. 4.5.b. level of recognision of trade unions as negotiating partners (do they meet, agreements in the social dialogue as compared to the labour standards) number of media outlets where collective bargaining between trade unions and employers took Draft 23/10/2013 16 place with a positive result. 4.5.c. Dynamics in numbers of journalists associated in a journalist unions. 4.d. Number of advocacy and lobbying initiatives undertaken in relation to the labour standards 4.e. Quality/ number of legal and social services for freelance journalists 4.f. Number of legislations on working conditions and social protecting and implementing in practice Draft 23/10/2013 17