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Source: United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA)
31 March 2008

What protection means for UNRWA in concept and practice

1. Introduction

1.1 The purpose of the consultancy of which this report is a product was to help develop an understanding of what protection means for UNRWA in its unique operational context and of how it can best become a part of the Agency's daily work.1 Implementation of the Organizational Development Plan (OD) provides significant opportunities in this regard. Protection is a broad concept: the focus of the report is on the particular needs that stem from the situation and vulnerabilities of Palestine refugees. Consultations were held within and outside UNRWA in each of the Agency’s five fields of operation. The departure point was that UNRWA’s protection mandate is inherent in the nature of its work: a “given” which the consultancy should help define but which does not need justifying.

1.2 Much work that is protection in the sense described herein is already being done within UNRWA. The report synthesizes and expands on this with the aim of providing a framework for a common understanding of protection, within which the related responsibilities of managers will be clear. Subsequent elaboration should help each staff member understand how her or his day-to-day tasks contribute to the protection of Palestine refugees. This should also help UNRWA develop an Agency-wide “protection reflex”, with staff alert to instances where the rights of individual refugees are threatened or violated, coupled with competencies and mechanisms to prevent or address those violations whenever possible.

1.3 Certain elements of the findings are highlighted in the form of recommendations. These do not in themselves constitute a summary: the report is intended to be read as a whole. An overview of the context in which UNRWA operates (section 2), focusing on the practical implications for protection, is followed by two sections on the meaning of protection for UNRWA, the first (section 3) identifying and the second (section 4) elaborating on four components. Section 5 considers the question of coverage – protection for whom? Section 6 covers working with others. Section 7 outlines priorities and flags some key considerations. Sections 8 and 9 address organizational implications, responsibilities, and accountability. Section 10 is a brief conclusion. A protection matrix, showing suggested responsibilities, is attached to the report.

2. The context

2.1 The context that determines the need for protection and the nature of UNRWA’s response has elements that are common to all five fields and elements unique to each field. Wherever Palestinians are, the failure over generations to find a just and durable solution to their plight determines and conditions their need for protection, as individuals, communities and a nation still without a State.

2.2 In all fields, the delivery of services is central to UNRWA’s activities. In Jordan and Syria the external environment in which services are delivered is not markedly different from that for nationals. In Lebanon refugees’ rights remain severely curtailed, law-and-order is not properly assured in the camps, and the threat of wider insecurity is present. In Gaza and the West Bank the actions of Israel, the Occupying Power, adversely affect the delivery of services.

2.3 The external environment increases both the difficulty and importance of delivering quality services to internationally agreed standards. Some services are life-saving. There is wide recognition of the critical importance of education not just for human development but as a resource for the future, one that by its nature lies within the control of Palestinians. Education is also a powerful protection tool. The need to deliver UNRWA’s services in a manner that respects the rights and ensures the security of beneficiaries and providers (themselves almost all Palestinians) is self-evident.

2.4 Refugees need protection because of an absence of national protection. Except in Jordan and Syria, where Palestine refugees enjoy a stable environment and some rights akin to national protection, statelessness compounds the effects of this absence. The protection needs of Palestine refugees in Lebanon are significant. They share with refugees in Gaza and the West Bank concerns related to internal political tensions, lawlessness and conflict. The central protection challenges in Gaza and the West Bank are, however, unique.

2.5 Three factors combine to distinguish the context in which Palestine refugees in the occupied Palestinian territory (oPt) need protection. First, there is the absence of a State that would, if it were so able, provide protection. The Palestinian Authority in the West Bank and the de facto authority in Gaza have clear responsibilities, but their ability to exercise effective control and provide protection is constrained by Israel. Second, Israel’s actions are not confined to addressing its security concerns but are also seeking to influence the configuration of any future Palestinian State. Humiliated Palestinian families are violently displaced and disposed of their homes, livelihoods and personal belongings. The illegal separation barrier and draconian restrictions severely constrain freedom of movement for Palestinians. Third, there are the effects of inter-Palestinian divisions and conflict. The protection challenges for humanitarian organizations inherent in the latter factors have parallels elsewhere: the uniqueness of the challenges in Gaza and the West Bank lies in the combination of all three factors, and in the extreme sensitivities inherent in the political context.2

2.6 Helping provide protection is further complicated by the fact that the acute humanitarian needs that result from the actions of Israel may obscure the latter’s obligations and those of others. UNRWA is providing essential services for which Israel either would otherwise be responsible or has a responsibility to facilitate delivery. In the West Bank, Israel is also failing to protect Palestinians from the illegal actions of its own citizens.

2.7 Neither humanitarian assistance nor international protection can substitute for, still less produce, a just and durable solution to the plight of Palestine refugees. This overriding need is therefore addressed first in the next section, notwithstanding the fact that it is the component over which UNRWA has least control.

3. Explaining protection

3.1 Put simply, protection is what UNRWA does to safeguard and advance the rights of Palestine refugees and thereby achieve its vision of every refugee “feeling assured that his or her rights are being protected, defended and preserved.”3 Only then can human development be fully assured. To explain what this means in practice, protection may be understood as having four components.4 Two have an external dimension and two an internal dimension.

3.2 The first component concerns the right of Palestinians to a just and durable solution to their plight. Achieving this is the responsibility of political actors: UNRWA’s role is to highlight the urgent need for that solution and to help ensure that in its elaboration the rights and interests of the refugees are safeguarded, with particular reference to those areas where UNRWA’s long experience with and knowledge of the refugees are relevant.

3.3 The second component covers protection for which the primary responsibility lies with the host government, Occupying Power, or authority or entity exercising de facto control. This component is commonly called international protection, the description used hereafter. Its content is determined by the special problems faced by Palestine refugees, outlined in the previous section. UNRWA promotes respect for their rights through monitoring, reporting and intervention. Interventions range from responses to specific problems, and preventive or remedial action when possible, to action to help create and consolidate an environment and practices in which rights are respected. UNRWA works with others to help ensure that Palestine refugees are protected.

3.4 Third, UNRWA has a direct responsibility for the delivery of its services in a manner that promotes and respects the rights and ensures the security of beneficiaries and of its staff. This is an integral part of ensuring the provision of quality services for the refugees in accordance with internationally agreed standards.

3.5 Fourth, UNRWA must ensure that protection needs are addressed in all aspects of programming, project design, policies, protocols and procedures, as well as in staff training.

Recommendation 1
UNRWA should understand protection in these broad terms.

4. The content

A just and durable solution

4.1 A just and durable solution is the key to the enjoyment of national protection and the realization of other rights. The UN has a political role in the efforts to this end. As a humanitarian and human development agency, UNRWA’s role is limited. But, having been created almost 60 years ago to support Palestine refugees pending such a solution, it is uniquely placed to highlight the need. The means may range from the public and private discourse of the Commissioner-General to ensuring that UNRWA’s activities are presented within this wider context, with the impact of the failure to find a solution reiterated rather than assumed as understood, and the limitations of UNRWA’s actions, particularly with regard to protection, explicit. At the same time, UNRWA should engage with those drawing up negotiating papers and proposing positions and policies in order to ensure to the extent possible that these take proper account of the rights and interests of the refugees and of UNRWA’s experience and knowledge. Primary responsibility for this component of protection rests with the Commissioner-General, her deputy and the General Counsel.

International protection

4.2 The challenges with regard to international protection for Palestine refugees include those common to protection for any refugees, for example: access to safety and services; identification and legal status; family reunion; detention without due process; constraints on or denial of freedom of movement; denial of fundamental rights; and the lack of law-and­order and functioning civilian authority in camps, and presence of armed elements in some. The degree to which such challenges are faced varies markedly between the fields.

4.3 The most acute problems are clearly those in Gaza and the West Bank, where the actions and pervasive influence of Israel create critical protection needs in addition to those inherent in the situation of all Palestine refugees. Other needs result from internal political conflicts and the manner in which power is exercised within the Palestinian communities. These needs cannot be isolated from the external environment: they are compounded by it, and compound its effect.

4.4 There are obvious and stark limitations in UNRWA’s ability to address many of these challenges. There are also solid foundations for action,5 and ways that the Agency can act, and is often already acting, to ensure that what UNRWA can do is done as effectively as possible. In many of them, the presence of international staff is a key element. Examples include: direct action to prevent or deter violations; monitoring violations and interventions to obtain remedial or corrective action; interventions to ensure due process and release from arbitrary detention; support and advice to individuals; reporting to bodies potentially able to affect protection outcomes, including therefore those whose recommendations are legally binding and require monitoring; advocacy at all levels, including through the media when appropriate; and direct or indirect engagement with host governments and the international community to promote the rights of Palestine refugees.

4.5 Promoting family reunion is a part of international protection, and unity of the family is a basic right. Some Palestine refugee families remain separated. Major obstacles are placed in the way of family reunion in the oPt and there are severe constraints on UNRWA’s ability to help overcome them. Where family reunion should take place elsewhere, UNRWA may be better placed to help achieve it, in cooperation with UNHCR when appropriate.

Recommendation 2
UNRWA should further develop policies and procedures that give priority to and help address the most acute needs for international protection.

Recommendation 3
In addition to field-level interventions, UNRWA should make increased use of the UN human rights system, concentrating on those mechanisms whose findings and observations carry most weight.

Protection in and through service delivery

4.6 In delivering services, UNRWA has direct responsibilities broadly analogous to those of a government’s health, education and social welfare authorities.6 The protection component of these responsibilities, as of those with regard to infrastructure and microfinance, is not a separate element within service delivery; it should be an integral part of a holistic approach to meeting individual and family needs and securing all their rights: their perspective must always be considered. Partnership with the community is an important element of this component of protection.

4.7 Lack of hope and denial of dignity, an external environment of calculated violence, and the unpredictable and arbitrary exercise and abuse of power all have a direct impact on the environment within the home, schools, health care and other facilities, and thus increase the challenge of this component of protection.

4.8 UNRWA’s direct responsibility is for those rights that are largely within its power to realize through the delivery of quality services to international standards. UNRWA’s services may provide an opportunity for the Agency to help promote other rights, as for example protection from abuse for refugee women and girls. While this involves responsibilities of a different degree for UNRWA, it does not affect how those in need of protection see their various needs.

4.9 Service delivery can help protect in other ways. Combined with targeted relief assistance and interventions, it can - for example - strengthen the ability of refugees in the West Bank to resist pressures that would otherwise achieve displacement. More generally, assistance that reduces the economic vulnerability of the poorest refugees is also likely to reduce their protection vulnerabilities. Conversely, protection activities may identify needs for special support, for example from social workers.

4.10 UNRWA has direct responsibility for the safety of its staff. Frontline delivery of services in the context already described brings its own protection needs. Some staff feel that the necessary support is lacking or inconsistent, with the burden of seeking redress placed on them, which may increase their vulnerability. A related concern is the perception that maintaining services in an environment not conducive to quality delivery and staff safety sometimes has a higher management priority than robust action to improve that environment or address immediate problems.

Recommendation 4
The terms of employment of staff delivering services should include a specific requirement to report any protection problems encountered, including abuses or violations against refugees or staff, and whether or not these are related to service delivery. This should be complemented by the necessary training. UNRWA should take effective follow-up action to deal expeditiously with the problem or concern reported, in accordance with well-promulgated procedures. These should minimize to the extent possible the exposure to abuses or pressures of staff making such reports.

4.11 The fact that UNRWA has both a direct responsibility for the proper delivery of services and responsibility to monitor and ensure that this takes place poses a particular challenge to the Agency, of which protection is only one element. Delivery should be monitored against internationally agreed standards (for example, those set out the Convention on the Rights of the Child and established by the WHO), and where appropriate against national standards. Progress should be measured against these standards and the indicators being revised through OD. This should be complemented by periodic outside review. Such monitoring and review would cover many potential protection concerns. Even in combination with the implementation of the recommendation above, this may not, however, be sufficient to ensure timely action: hence the following recommendation.

Recommendation 5
UNRWA should examine the possibility of developing (or incorporating in suitable existing arrangements) mechanisms that help individuals report any protection concern, whether related to service delivery or not.7

Programming protection

4.12 A shared understanding of the content of protection will allow UNRWA to extend rights-based programming of its services, within the human development framework, so as to ensure that all protection needs are addressed in its programming, policies and staff training. Elements of what this involves are situation-specific, but the general principles are well established, whether already within UNRWA or by others (for example in addition to the guidelines on rights-based programming, there is a wide range of handbooks that cover or include practical protection considerations). The implementation of OD provides the opportunity not only to introduce but also to integrate protection considerations in the programme management cycle. This is the only one of the four components of protection over which UNRWA has full control.

5. The coverage: protection for whom?

5.1 The first component of protection concerns all Palestinians and the third by definition covers beneficiaries of UNRWA’s services. This question arises with respect to the second component. UNRWA’s focus is on the needs among registered refugees, but other Palestinian civilians in Gaza and the West Bank have similar needs for international protection, as they do elsewhere, particularly in Lebanon. This component of protection responds to needs inherent in the situation of an individual (in this there is a parallel with refugee status under international refugee law, which is recognized by a government or UNHCR, not a status conferred by them).

5.2 In certain circumstances, UNRWA’s emergency assistance and some services extend to other Palestinians.8 The degree to which UNRWA’s protection activities do likewise should be determined by the specific nature of the needs and UNRWA’s capacity to meet them or mobilize others who may be better placed. UNRWA already assesses the protection needs of the civilian population rendered vulnerable by the conflict.9

6. Working with others

6.1 UNRWA works closely with the relevant authorities to help provide protection for Palestine refugees. Many international and non-governmental organizations are involved in different activities relevant to protection. UNRWA works with others to help ensure that protection activities are coherent, complementary and coordinated, and that to the extent possible the resources needed are available and deployed effectively. In accordance with their respective responsibilities,10 UNRWA and UNHCR work to ensure that all Palestinians requiring protection receive it. The need for close cooperation with ICRC is evident, for example with respect to emergency responses and detention of refugees. The importance of working with the refugee community has already been underlined.

6.2 UNRWA and UNICEF are working closely on child rights, a relationship that is particularly important in (but not limited to) the context of aspects of service delivery. Rights-based non-governmental child protection (and other protection) organizations have an important role to play, and their potential is not yet properly exploited. Such contributions and partnerships should be actively encouraged. In those fields where international protection is most needed, cooperation with OHCHR is essential, including at the operational level, in advocacy, and in higher-level interventions.

6.3 The scale of the protection challenges in the oPt and Lebanon gives particular weight to action to avoid either duplication or gaps among the various protection activities. UNRWA is an active participant in the mechanisms established to this end. For the oPt, OCHA is well placed to consolidate relevant information (and OCHA’s maps represent a valuable tool for indirect protection). UNRWA is already cooperating with many community-based, national, and international NGOs, and should build on this and help expand protection coalitions on the ground.

7. Priorities and key considerations

Setting priorities

7.1 Given the size of the protection challenges relative to UNRWA’s resources, it is clear that priority must be given to the most acute needs, to those actions likely to have the greatest impact on meeting these, and to reinforcing and building partnerships with others, as discussed in the previous section. Action to ensure that services are delivered in facilities that are free of violence and intimidation and in a manner that identifies and meets the needs of the most vulnerable, and responds effectively to new vulnerabilities, has rightly been identified by UNRWA as a priority across all fields.

7.2 Some of the most acute needs in the oPt are being created by calculated acts rather than as a consequence of a complex and not fully controllable environment. The long-term human cost of forced displacement gives high priority to preventive action, and - if prevention fails - to action to mitigate and redress where possible both the immediate and longer-term effects. The situation of Palestine refugees in Lebanon is in part explained by the complexity of the environment, but their plight makes continuing action to secure their rights, and to support the establishment of the rule of law and civilian authority in the camps, another high priority.

7.3 Within UNRWA, an evident priority attaches to action to elaborate a protection strategy and integrate protection. Best use must be made of the very significant potential of the service delivery to support and inform protection activities, and of these activities to support service delivery to the desired standards.

Key considerations

7.4 Whatever the priorities, which only UNRWA itself can set, there are certain key considerations. Many aspects of protection require accurate and timely information. The credibility of an intervention may be compromised if simple details are wrong. In some circumstances, its effectiveness may suffer if it is delayed: it may be better to act quickly on incomplete information, acknowledging the gaps, than wait. Accurate and timely information must reach those best placed to make use of it.

7.5 Protection should be consistent across UNRWA: a similar challenge should produce a similar response (one that reflects best practice). That response should be predictable: those contemplating or undertaking actions that may adversely affect refugees should know what response to expect from UNRWA. Even if this knowledge does not in itself moderate behaviour, it will help focus attention on substance not form. Finally, it is important for UNRWA to be realistic about its ability to deliver protection, and not to raise false expectations.

8. Organizational implications

The OD and strategies

8.1 If UNRWA’s protection mandate is a given, and is understood in the broad terms set out herein, this has implications for the Agency’s strategic direction. For example, the first fundamental element guiding UNRWA’s work could be expanded (the italics) on the following lines:

This addition is already reflected in the third component of UNRWA’s vision, but protection is subsequently seen as one part of rights-based programming, listed as a commitment along with gender mainstreaming, youth, and groups with special needs.12 In the Interim Programme Strategy for 2008-2009, “Incorporating protection strategies” is a strategic theme, along with “Planning for inclusion”, “Ensuring gender equality” and “Protecting the Environment”. (The need also to pay particular attention to the vulnerabilities of the aged was highlighted in a number of consultations.)

8.2 The IASC definition of protection used in UNRWA documentation is generic. Given that UNRWA’s protection mandate is inherent in the nature of its work, an UNRWA-specific short description may be helpful in explaining protection within the Agency. For example, in language already used above:
8.3 As noted in the introduction, once a framework for a common understanding of protection and related responsibilities is agreed, this will require elaboration in a protection strategy that allows staff to understand how their work should contribute.13 While staff resources will need to be dedicated to the task, the development of this strategy is a shared responsibility of management.

Recommendation 6
UNRWA’s commitment to protection should be further elaborated in a protection strategy, and find expression in its key Agency-wide documentation and in field-specific strategies as these are updated.14

Structure and staff

8.4 The structuring and staffing of protection must take account of field-specific considerations (as well as the need for harmony across fields), organizational priorities and the wider OD process (and reflect a deeper understanding of the issues than has the consultant). The proposals that follow should be considered with these qualifications in mind.

8.5 Protection is better conceived as an operational line management responsibility than as a specialist function, though it needs specialist oversight and support. Protection concerns are present in all aspects of programme delivery, and are best addressed by locating clear management responsibility as close as possible to the need and to sources of information on potential needs. This key task would appear to fit well with a redefined role and increased authority for Area Officers, as operational managers as well as coordinators and monitors. With the necessary training, they would be well placed with respect to both international protection and the monitoring of the protection aspects of service delivery.

8.6 Area officers – any locally-based managers – need international support and cover from the pressures inherent in operational protection, and international protection needs international staff on the front line. In Gaza and the West Bank, UNRWA has a valuable resource in the Operations Support Officer (OSO) programme: OSOs are effectively roving international protection officers. They are also well placed to (and to an extent already do) develop practical links with other bodies involved in protection activities among and with the communities.

8.7 There is scope to exploit further the potential of the OSOs, and a need to expand such an international presence on the ground wherever this is warranted by the nature of the protection challenges. For example, a team of at least four OSOs, with the necessary dedicated logistical support, could play an important role in helping address the challenges in Lebanon. Once the need for and functions of such international staff are presented, it is likely that further donor support would be forthcoming.

Recommendation 7
The Area Officers (or any other solution developed under OD to meet the need for properly empowered managers located close to the refugees) should have responsibility for delivering protection, and where necessary international staff (either from the OSO programme or additional resources) should be assigned to support them.

8.8 A dedicated protection coordinator should be appointed in those field offices facing significant protection challenges: currently, Gaza, Lebanon and the West Bank would have priority (elsewhere, a protection focal point may suffice). This person would be responsible for supporting area-level protection activities and for ensuring that these reflect the field and Agency’s priorities, and are undertaken within a framework that provides clear guidelines, a common methodology and standardized reporting. The field protection coordinator would manage and analyse protection data, and prepare and follow up on field-level interventions. There are already staff discharging some of these responsibilities, and it may be possible to implement this proposal within existing resources. If not, this too should find donor support.

8.9 It follows that the recently established P-5 SPPA protection post should be re-titled Senior Protection Coordinator (SPC hereafter), with responsibilities at the Agency-level broadly similar to those of the proposed field-level protection coordinators. The SPC would be responsible for coordinating preparation of the protection strategy and for the further development of Agency-wide protection policies and procedures, reflecting best practice, as well as for protection training. The SPC would be supported by the Chief of the International Law Division and the Coordinator of Programme Support and their colleagues. The General Counsel would of course retain overall responsibility for ensuring that UNRWA’s protection policy and practices are in conformity with international law and the principles of the UN.

8.10 There are several possible locations for the SPC. The strongest case appears to be for locating the post in the Jerusalem Office of the Commissioner-General. This rests primarily on the need for protection to be seen as indeed a fundamental element guiding all UNRWA’s work. That location would also provide synergies with the emergency, programme coordination and support, and OD functions already reporting to the Deputy Commissioner-General.

Recommendation 8
Support and oversight for protection activities at the area level should be provided by field protection coordinators, and at the Agency level by a senior protection coordinator.15

9. Responsibilities and accountabilities

9.1 Responsibilities and accountabilities are being elaborated or redefined within the framework of the OD process. This section provides a brief overview from the protection perspective. An important aim of this report is to help clarify the responsibilities of senior management. The preceding section has outlined suggested responsibilities for protection staff. All staff involved in the delivery of services have a protection responsibility, as has already been explained.

9.2 Practical protection involves every staff member who comes into contact with a person in need thereof or with a situation requiring a protection response. Timely and effective action by the staff member may be of critical importance to the outcome. This is the Agency-wide “protection reflex” referred to in the introduction. The nature of the staff member’s responsibility will be determined by her or his position in the Agency and by the specific situation.

9.3 UNRWA is directly accountable for the proper delivery of services. The particular context in which UNRWA operates places severe limits on its ability to provide international protection. UNRWA as an agency and its staff as individuals are accountable for making the best possible use of the protection that is within their power to deploy or mobilize, and for ensuring the most effective protection possible in the prevailing circumstances.16

10. Conclusion

10.1 The previous section explained how any staff member may have a protection role to play. Responsibility for protection is indeed inherent in the work of UNRWA, to be discharged at all levels through the leadership and initiatives of individuals as well as through organizational structures. A better integration of protection into UNRWA’s activities is necessary, and already underway. There is presently an opportunity to significantly advance that task. This is an opportunity that the Agency must seize, and is fully capable of seizing.

Explaining protection

Protection is what UNRWA does to safeguard and advance the rights of Palestine refugees and thereby achieve its vision of every refugee feeling assured that his or her rights are being protected, defended and preserved.

1 The consultancy was undertaken over a period of two months by Nicholas Morris, a retired UNHCR staff member. The assistance and advice of many UNRWA staff members is gratefully acknowledged. Their views and comments inform the report throughout. Responsibility for the use made of them is the consultant's alone.
2 This context challenges the principles and practice of UN humanitarian organizations, as for example on non­discrimination, access, and engagement with any entity whose actions affect the protection of civilians, on the sole criterion of the needs of those civilians.
3 UNRWA’s Interim Programme Strategy 2008-9 (24 Sept 07), 1.2.
4 This presentation covers the key elements and is, it is hoped, an accessible way of looking at the issues. Content is, of course, more important than labels or presentation.
5 International protection rests on legal instruments and obligations that engage the responsibility of those exercising control. Political actions, the exercise of power and the use of force all bring with them responsibility for their humanitarian consequences. UNRWA helps deal with these consequences, and its legitimate concern with the proper discharge not only of legal obligations but also of this responsibility may help reinforce some interventions.
6 However, UNRWA lacks legislative and other authority relevant to the discharge of these responsibilities.
7 These could perhaps be based on a ‘hotline’, given the widespread access to a mobile phone.
8 And even exceptionally to non-Palestinians.
9 See the 2008 Emergency Appeal, page 26.
10 These are set out in the January 2007 joint booklet The United Nations and Palestinian Refugees.
11 Original text from page 10 of UNRWA’s Organizational Development Plan 2007-09.
12 Of the 24 focus areas listed for the five fields in Table 2 of the Interim Programme strategy, only one is directly protection-related (Jordan: the need to address the specific problems of the holders of two-year temporary passports).
13 In addition to the strategy, an initial implementation plan will be required.
14 As it should when the Secretary-General’s bulletin (ST/SGB/2000/6) is next updated.
15 The protection coordinators should have relevant operational experience (e.g. as would be gained in the field with ICRC, an operational UN human rights mission, or UNHCR). The organizational location of the post would be determined by the structure of individual field offices. The SPC should additionally have appropriate experience in managing and coordinating protection at a country-wide level.
16 The primary external accountability for protection is of course towards those in need of it.

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