POLICY BRIEF Implementing the United Nations Global Compact on Refugees? Global Asylum Governance and the Role of the European Union - ASILE Project
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POLICY BRIEF Implementing the United Nations Global Compact on Refugees? Global Asylum Governance and the Role of the European Union 1. Introduction: ‘Contained mobility’ The ASILE project studies the changing relationship between containment and mobility amongst the key asylum governance in- struments and actors from both an international comparative and European Union (EU) perspective and from the European Union (EU). It aims to inform the EU’s role in the implementation of the United Nations Global Compact on Refugees (UN GCR). This Policy Brief outlines and synthesizes the preliminary findings and policy recommendations emerging from the first 18 months of the ASILE project which started in December 2019. There has been a substantial body of scholarly literature on the practices and legality of containment in migration instruments. Containment policies are characterised under various labels. These include non-entrée, non-admission, non-arrival, deterrence and deflection, as well as source-control and delegated contain- Authors Sergio Carrera, Lina Vosyliute, Leiza Brumat and Nikolas Feith Tan1 1 Sergio Carrera is the Scientific Coordinator of the ASILE H2020 Project. He is Senior Research Fellow and Head of Unit at CEPS, Part-time Professor at the Migration Policy Centre (MPC) of the European University Institute (EUI) and Visiting Professor at the Paris School of International Affairs (PSIA) in Sciences Po. Lina Vosyliute is Research Fellow at CEPS. Leiza Brumat is Research Fellow at the Migration Policy Centre (MPC), EUI. Niko- las Feith Tan is Senior Researcher at the Danish Institute for Human Rights (DIHR). For more information about ASILE see: www.asileproject.eu The authors would like to express their gratitude to Professors Andrew Geddes, Gregor Noll and Maja Janmyr for their com- Issue 2021/26 ments and suggestions on a previous draft version of this Policy Brief. The authors would June 2021 also like to thank Andrew Fallone for contributing to the formatting of the list of references. The ASILE project has received funding from the European Union’s Horizon 2020 research and innovation programme under grant agreement nº 870787. This document reflects only the author’s view and the Commission is not responsible for any use that may be made of the information it contains.
ment policies directed at the countries of origin of from international protection. However, exclusion- refugee flows (Aleinikoff, 1992; Shacknove, 1993; ary features and constraining dynamics of contain- Noll and Vedsted-Hansen, 1999; Moreno-Lax and ment are still at play in their rationale, operational Giufree, 2017). design and/or practical implementation dynamics and actors. ASILE provides a critical analysis of a wide range of policy, legal, financial mobility and inclusion in- struments that have been officially portrayed as 2. Critical Assessment of ‘Promising ‘promising practices’ by the UN GCR in in coun- Practices’ around the World tries like Brazil, Canada, Jordan and South Africa. With regards to Refugee Status Determination These include resettlement, community or private (RSD), the ASILE project confirms the large mar- sponsorship, humanitarian admission or dispen- gin of discretion and lack of transparency affect- sation programmes, and economic investment or ing current RSD procedures which have already trade deals focused on labour market integration been identified in the literature (Costello, Nalule in refugee-hosting countries. and Ozkul, 2020). The Project is paying attention to the exclusionary and inclusionary components The ASILE project unpacks these practices and in- of individual RSD procedures under the 1951 Ge- terrogates the rationales upon which they are pre- neva Convention standard compared to group- mised, and their inclusionary or exclusionary com- based RSD adopted by countries like Turkey (Ine- ponents: do they facilitate agency, mobility and li-Ciger and Yigit, 2021) or Brazil (Medina Araújo, the international protection of asylum seekers and 2021). The research is also exploring the roles refugees? What are the context and region-specif- of UNHCR in states that are not signatory to the ic parameters characterizing the dynamics of their 1951 Geneva Convention such as Bangladesh scope and local implementation? Does the design (Uddin Khan and Mahbubur Rahman, 2021; and and its effects serve the purpose of containment Hossain, 2021). or does it run contrary to international and region- al refugee and human rights standards? ASILE The private or community sponsorship model im- country-specific research demonstrates that in- plemented by countries like Canada constitutes struments or tools formally understood or framed an example of a policy which is often considered as ‘mobility or inclusion’ such as “complementary as “promising”. ASILE research warns that the pathways” present some ‘containment-driven’ fea- Canadian private sponsorship model has the po- tures, leading to instances of individual exclusion tential to “download and privatise what should be and restrictions of refugees’ agency (ASILE Coun- a public responsibility to resettle refugees thereby try Fiches). replacing a public commitment with a private char- ity” (Macklin and Blum, 2021). Community spon- Our research indicates that while complementary sorships can be successful when implemented pathways instruments feature some relevant in- alongside publicly funded resettlement schemes, clusionary or protection-driven components, they and when they ensure non-discriminatory access also display a set of exclusionary features which and conditions (Tan, 2021b). operationalise hierarchies of deservedness and temporariness, and lead to discrimination (Mack- An additional example of a “complementary path- lin and Blum, 2021; Tsourapas, 2021; and Medi- way” instrument is the Zimbabwean Dispensa- na Araújo, 2021). This trend is also apparent in tion Programme (ZDP) (Khan and Rayner, 2021). the EU (See Section 4 of this Policy Brief below), ASILE research has revealed that the programme where the resettlement of refugees has been pro- was not meant to relabel refugees as ordinary moted as the key legal pathway but mainly as part migrants. Yet, “many Zimbabweans who came of a broader migration management and contain- to seek asylum in South Africa felt compelled to ment agenda with third countries (Carrera and transfer to the Zimbabwean Dispensation Pro- Cortinovis, 2020). gramme” and fall under an economic migration status rather than refugee protection status. The ASILE shows how these asylum governance in- ZDP provided a greater security of residence with struments might be better understood through the a 4 years residence work permit when compared lens of a ‘contained mobility’ paradigm (Carrera with the asylum seekers permit which is valid for and Cortinovis, 2020). ‘Legal or complementary 3 to 6 months. Thus, de facto ZDP has become pathways’ instruments envisage or allow for some a complementary pathway for refugees and other limited or highly selective mobility and socio-eco- people looking for international protection. nomic inclusion of people looking for or benefiting 2 Robert Schuman Centre | June 2021
situation allows them to. The situation for refugee livelihoods in Jordan has considerably worsened LESSONS LEARNED since the Covid-19 pandemic (Turner, 2021). The focus on creating employment for Syrians has led Community Sponsorships to the emergence of an uneven playing field Community sponsorship is a flexible mobili- among refugees and migrants of other na- ty approach that may either be a standalone tionalities. Furthermore, the Jordan Compact complementary pathway or a form of reset- serves the objective of migration deterrence tlement. The New EU Migration and Asylum for Syrian refugees not to move into the EU Pact aims to develop a ‘European model of (Fakhoury, 2021). community sponsorship.’ Based on the Ca- nadian experience and lessons learned from The way in which South American countries have recent European pilots, the introduction and dealt with the Venezuelan crisis has presented expansion of community sponsorship in the some interesting insights for the EU (Brumat and EU should be undertaken in line with the fol- Freier, 2021). Brazil has granted residence per- lowing principles: mits based on both the expanded definition of refugee of the Cartagena Declaration and on the • ‘Additionality’ to existing resettlement application of the Residency Agreement of MER- programmes; COSUR (RAM) in order to deal with one of the • Non-discrimination between refugees largest influxes of forcibly displaced people in the in terms of selection and standards of history of the region. This has allowed the Brazil- treatment; ian state to reduce the backlog of residence and refugee requests while the RAM has provided an • Protection-focused, not primarily for pur- alternative to formal refugee protection (ASILE poses of labour or education migration; Country Fiches; ASILE Book on the EU Pact and the UN GCR; and Brumat 2021). • Clarity of legal status for sponsored ref- ugees; and • Transparency and accountability, LESSONS LEARNED through a robust legal or policy frame- work (Tan 2021a). South American Responses In the face of large-scale displacement of Venezuelan citizens, South American bor- The “Jordan Compact” of 2016 has been framed as ders remained largely open, as govern- one of the main responses to the so-called ‘Syrian ments recognized that it is not possible to crisis’. Although the Jordan Compact came along prevent border crossings. Brazil provides with a promise of resettlement, its main focus is residence permits to Venezuelans based on still on refugees’ labour market integration as ‘de- migration (following the RAM) and refugee terrence’ to onward mobility towards the EU. It is status. This provides them with the right to therefore different from complementary pathways work and security of residence. Despite this, focused on mobility. The economic investments a large part of the Venezuelan displaced “have unlocked the potential to further support population works in the informal market. forcibly displaced populations” (Tsourapas, 2021). Nevertheless, the main note of caution is that such strategies seem to work only in the short-term, as political attention and funding over time are fad- ing from Jordan. Despite this, the needs of asylum and refugee will persist long-term. The main challenge characterizing the Jor- dan Compact is impractical socio-economic inclusion in a fragile local labour market and insecurity of residence. This is because Syrians are expected to repatriate from camps once the 3 Implementing the United Nations Global Compact on Refugees?
The RAM provides a two-year residence permit management in fundamental ways. This has neg- which can be turned into a permanent one after ative implications on individuals, and their agen- providing a proof of employment or other subsis- cy, as it reframes people with legitimate claims tence. However, ASILE research on Brazil shows for international protection as “migrants”. It also that having regular status in Brazil is not neces- affects how state actors consider their discretion sarily a guarantee of employment (Medina Araujo or sovereignty with regards to controlling the en- 2021). Unlike the case of the Zimbabwean Dis- try of foreigners in order to exclude people seek- pensation Programme, which is purely labour-re- ing international protection guaranteed by human lated, Venezuelans are not compelled to apply for rights instruments and the rule of law, where nor- migratory status instead of refugee status. The mally no derogation is permitted. ASILE research choice between obtaining regular status as a refu- highlights that the emphasis put on the “right of gee or migrant is not closely related to the reasons states to control migration” prioritises states inter- why the person left Venezuela. Rather, the choice ests over human rights and essential rule of law depends on the economic status of the person guarantees (Spijkerboer, 2021). because applying for refugee status is significant- ly cheaper than applying for migrant status. The The answer to the labelling question is central choice can also depend on mobility opportunities when identifying the applicable set of international because refugees cannot return to Venezuela and and regional legal standards, the related package many people would prefer to go back temporarily of human rights granted to individuals in interna- for various reasons, such as to visit their relatives. tional law, the obligations of (and potential respon- sibility by) state authorities and the roles of inter- ASILE research highlights the central importance national organisations (such as UNHCR or IOM) of ensuring adequate security of residence and a in the implementation of asylum policies. decent right to work – as a “composite right” com- prising “both the freedom, accessibility and qual- ASILE examines the extent to which the use of ity of work”. This is because they are essential to labels is related to relevant actors: who frames ensuring international protection and socio-eco- knowledge and priorities in these policy domains? nomic inclusion (Costello and O’Cinnéide, 2011). What are the roles and competences of these ac- The inclusionary components of group-based rec- tors on asylum and migration management (and ognition instruments and procedures, which are capital, e.g. funding)? Who implements relevant currently under-appreciated, calls for further re- policies and projects on migration and refugees? search. However, group-based RSD runs the risk Are attempts to reframe statuses a conscious or of curtailing legally binding socio-economic rights, instrumentalist effort by relevant states actors to freedom of movement and family life, and family limit their responsibilities in light of international reunification rights when compared to individu- refugee law (1951 Geneva Convention) and hu- al-based refugee statuses. man rights law and restrict individuals’ rights. 3. Migrants or Refugees? Rethinking People in Asylum Governance ASILE research reveals a problematic reframing or relabelling of people in asylum governance instruments across all countries covered in the ASILE Country Fiches. Individuals looking for in- ternational protection, and particularly those who arrive spontaneously, are given different labels and statuses by national authorities which depart from the Geneva Convention’s refugee status. These include other labels such as ‘forced mi- grant’, ‘forcedly displaced person’ or ‘temporary protection beneficiaries’ (ASILE Country Fiches) for which no commonly or internationally rec- ognised definition exists. Relabelling individuals’ statuses runs a profound risk of blurring refugee protection with migration 4 Robert Schuman Centre | June 2021
The ASILE Country Fiches show the key protec- an obligatory principle aimed at ensuring state tion-enhancing role played by (1) national courts accountability in cases of human rights and ref- that adjudicate justice for people looking for inter- ugee protection violations. ASILE’s research is national protection through a constitutionality test highlighting the need for the EU and UN members and by upholding international refugee-protection to play a more active role in upholding refugee standards (e.g. Canada, Bangladesh or South Af- protection and human rights obligations that are rica)2; (2) international and regional human rights mandatory. International or regional legally bind- monitoring bodies in keeping states accountable ing commitments are not a matter of choice and (ASILE Country Notes on “International protection flexible responsibility cannot be applied. issues and recommendations from international and regional human rights mechanisms and bod- The new EU Pact understanding of the solidarity ies” available in the ASILE Portal); and (3) civil so- principle is also detached from individuals and the ciety actors (CSAs) and human rights defenders, role of civil society. This was synthesised by a rep- especially those engaged in the promotion and resentative of the Global Refugee Network at the monitoring of human rights and refugee protection ASILE First Annual Conference who stated “noth- standards compliance by states actors. ing about us without us”. Therefore, it is crucial that refugee voices and civil society find a place and active role in conceptualising and assessing 4. Principles contested asylum instruments. The UN GCR is anchored by a set of guiding prin- The principles or notions of ‘vulnerability’ and ciples. Paragraph 5 of the GCR emphasises that ‘self-reliance’ of refugees raise similar open ques- “The Global Compact emanates from fundamen- tions. ASILE research addresses how migration tal principles of humanity and international solidar- and asylum management policies actually co-cre- ity, and seeks to operationalise the principles of ate the vulnerability of particular people looking for “burden- and responsibility-sharing” to better pro- international protection. The project emphasises tect, assist refugees and support host countries the importance of distinguishing between struc- and communities.” The actual meaning and scope tural and individual vulnerabilities (Costello and of these principles are, however, far from uncon- O’Cinnéide, 2011) tested. ASILE investigates whether structural vulnerabili- While solidarity is one of these often-quoted con- ty is generated by laws and policies, and render- cepts, this notion sometimes pursues or conveys ing individuals and families vulnerable to certain ‘inter-state responsibility sharing’, a ‘responsibility harms and insecurities (Costello and Freedland, shifting’ agenda and a state-centric understanding 2016). This approach does not assume that wom- and framing of responsibility in relation to interna- en and girls, minors or LGBTIQ+ individuals are tional protection (Byrne, Noll and Vedsted-Han- per se more ‘vulnerable’ than other people are in sen, 2020). For instance, in the new EU Pact the general. Instead, the Project addresses the ques- Commission called for ‘mandatory flexible soli- tion of ‘vulnerable to what’ as this allows for a darity’ which allows the Member States to choose more nuanced and intersectional analysis of vul- between participating in the relocation of asylum nerability. seekers, ‘return sponsorships’ or capacity building and operational support (Vosyliūtė 2021). The Project assesses the role of the law in limiting and/or enabling decent work for refugees. ASILE Solidarity is wrongly framed as something volun- Country Fiches show how the notion of “self-reli- tary and follow a ‘pick-and-choose menu’ or per- ance”, including calls for refugees to swiftly “inte- ceive it as a charity-based option as opposed to grate into the labour market” are often examples 2 The ASILE Country Fiche on Canada states that “In July 2020, the Federal Court ruled that the Canada-US Safe Third Country Agreement (STCA) violates the Canadian Charter of Rights and Freedoms, basing its judgment primarily on the punitive use of detention by US au- thorities against asylum seekers returned to the United States by Canada”, page 7. According to the ASILE Country Fiche on Bangladesh “The High Court Division of the Supreme Court of Bangladesh in the case of Refugee and Migratory Movement Research Unit (RMMRU) vs. Government of Bangladesh (2017) has held that Article 33 of the 1951 Convention relating to the Status of Refugees has become a part of customary international law and accordingly binding upon Bangladesh.”, page 9. Similarly, The ASILE Country Fiche on South Africa identifies as Ruta v Minister of Home Affairs (2018) as a seminal case in refugee law “as the Constitutional Court reaffirmed the importance of non-refoulement, limited the definition of an illegal foreigner and affirmed previous cases of High Courts and the Supreme Court of Appeal concerning containment practices.”, pages 10-11. 5 Implementing the United Nations Global Compact on Refugees?
of deterrence-driven migration policies, as is the When cooperating with third countries often char- case in Jordan (Tsourapas, 2021). In other cases, acterized as ‘transit’ states, the EU integrates it may only allow access to decent work for some non-migration related policies such as trade, de- beneficiaries of international protection or residen- velopment, humanitarian aid and investment with cy status under structurally discriminatory condi- a migration management and policing rationale. tions. ASILE research demonstrates that the right This conflicts with fundamental human rights and to decent work in international human rights law, the rule of law. EU third country arrangements in particular its ‘minimum core’, applies to asylum with African countries do not consider the different seekers and refugees and that many contempo- interests, normative outlook, regional integration rary restrictions on asylum seekers and refugees’ or human rights systems on cross-border human access to work are in breach of International Cov- mobility (ASILE Book on the EU Pact and the UN enant of Economic, Social and Cultural (ICESCR) GCR). and regional human rights standards (Costello and O’cinnéide, 2011). EU external migration policies show a strategic use of non-binding political and financial instru- In some national instruments, international pro- ments – often termed ‘arrangements’ (Tan and tection safeguards that are traded for immediate Vedsted-Hansen, 2011). The essential character- access to the labour market does not always en- istic of these arrangements is that of ‘informality’ sure a decent right to work and non-discriminatory as they do not qualify as international agreements standards (Medina Araújo, 2021; Ineli-Ciger and or EU law. The informal nature of such agree- Yigit, 2021). Representatives of the ASILE Civ- ments mean that it is unclear whether the content il Society Group have underlined that the critical of the agreements is legally binding, and if so, obstacles to a decent right to work are structural under which body of law. Informality is evident in discriminations and injustice; language barriers; the EU’s reliance on third countries in readmission and lengthy and complex recognition of qualifi- arrangements, the so-called ‘fight against migrant cations. Some individuals under specific national smuggling’, and human trafficking and border instruments can get trapped between poverty and management. In EU external relations on migra- destitution, exploitative labour conditions and /or tion such informality poses fundamental challeng- the non-refoulement principle. es to the rule of law, and particularly legal certain- ty, democratic accountability and judicial control. 5. The EU’s Role in Implementing The New EU Pact still promotes one of the most the UN GCR well-known EU ‘arrangements’, the 2016 EU-Tur- The EU’s arrangements with third countries and key statement, as a ‘solution’ that stemmed the the New EU Pact on Migration and Asylum pres- number of irregular entries by people looking for ent a similar containment-driven logic. ASILE re- international protection. ASILE Research shows search argues that this challenges both the UN that this disregards the relevance of other factors Global Compact on Refugees (GCR) and the ob- that played a key role in preventing spontaneous jectives and founding principles of the UN Global arrivals, such as the so-called Western Balkans Compact on Migration (GCM) (Carrera and Ged- Route Statement (Spijkerboer, 2016; Tan and des, 2021). Vedsted-Hansen, 2011 and Ineli-Ciger and Ulu- soy, 2021). The key foundational legal principles reflected in the UN GCR, such as the rule of law, democrat- It is now evident that EU arrangements are charac- ic accountability, human rights and the primacy of terized by legal uncertainty, are vulnerable to polit- refugee protection, are not sufficiently reflected in icization and create a problematic dependency for the New EU Migration and Asylum Pact. Instead, the EU on third country government’s ‘good will’ the Pact prioritises localisation and speed and ex- to cooperate in the containment of refugees and ternalisation. This raises central questions in rela- migrants. The extent to which arrangements like tion to the legal responsibility and accountability the EU-Turkey statement co-creates ‘crisis’ has of state authorities and other implementing actors been largely ignored and should also be another (including EU Agencies like Frontex and EASO) in important lesson learned in the EU’s role when im- cases of human rights violations and/or non-com- plementing the UN GCR (Cortinovis, 2021). pliance with EU law (Carrera, 2021). ASILE research has identified many issues in need of greater scholarly attention, in particular in relation to the ‘informal’ economy, gendered and 6 Robert Schuman Centre | June 2021
racialized divisions of labour, and the role of law in This mechanism would be a venue for formal ex- both limiting work rights and enabling decent work changes, including joint fact-finding missions, and (Costello and O’cinnéide, 2011). The UN GCR strategy-setting on key issues and challenges; runs the risk of blurring refugee protection from promising practices and lessons learned; and as a legal commitments. However, for these processes way to follow up of UN GRF political commitments to be meaningful and effective, establishing par- and pledges by governments. ticipatory forms of independent monitoring is vital, as are clear commitments rooted in legally binding 3. The principle of ‘solidarity’ needs to be recon- human rights and refugee protection standards. sidered and critically examined so that it does not blur States’ legally binding human rights and refu- The EU is a crucial actor in this regard; not only gee protection commitments, and moves beyond because its Member States host many asylum a shifting statist focus on responsibility sharing. seekers and refugees but also because its asy- A human rights and rule of law-centred approach lum policies are widely emulated internationally should inform the scrutiny of national, regional and so can be expected to have global impacts. and EU policies in light of the UN GCR. Moreover, the EU plays a key role in international processes that seek to leverage better protection 4. ASILE research is highlighting the central im- for refugees in the main host states outside the portance in ensuring the security of residence, EU. ASILE research highlights that if these pro- including expanding the length of work/residence cesses are to improve refugees’ lives, a human permits; and the right to decent work. This in- rights-based approach to the right to work is vital. cludes the need to consider the specificities of national and local context in relevant policies and their effects before labelling them as ‘promising 6. Policy Recommendations to the practices’ for UN GCR purposes and assuming EU their transferability to other regions and countries. 1. Mobility and inclusion instruments should com- EU policies should also be informed, reviewed ply with the following key features: first, they must and monitored based on the actual experiences, not be discriminatory either in nature or effects; desires, self-organization, and self-mobilization of second, they need to follow a principle of addition- refugees and international protection beneficia- ality so that they are not a substitute or alternative ries. to the right to seek asylum and spontaneous ar- 5. The implementation of the EU Pact on Migra- rivals; third, they must be protection-driven; and tion and Asylum should focus on initiatives and fourth, they cannot substitute states’ public re- projects that prioritize legal certainty, access to sponsibilities towards asylum and refugees and justice, effective remedies by people looking for their resettlement. international protection, and the independent 2. In addition to effective judicial protection and monitoring of Member States and EU agencies’ scrutiny, democratic accountability plays a cru- compliance with legally-binding international and cial role in upholding states’ implementation and EU human rights and rule of law. The EU should follow up of their legal and political commitments improve the design and effective implementation and pledges under the UN GCR and Global Ref- of human rights and refugee protection Impact As- ugee Forum. The active contribution of national sessments (IAs) and independent monitoring tools parliaments across relevant world regions could and provide evidence on the actual impacts and be further fostered in this respect. The European practical effects of EU migration and asylum gov- Parliament could more actively support and op- ernance legal, policy and financial instruments. erationally implement ‘parliamentary diplomacy’ This should include evidence on their compliance with other relevant transnational parliaments (e.g. with the rule of law and the EU Charter of Funda- the African Inter-Parliamentary Union, IPU). mental Rights. This would facilitate region-to-region parliamenta- ry exchanges and democratic accountability for the UN GCR implementation processes and EU-third country migration and asylum instruments and ar- rangements. This could take the shape of a per- manent inter-regional parliamentary mechanism on refugee protection and forced displacement. 7 Implementing the United Nations Global Compact on Refugees?
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Migration Policy Centre The Migration Policy Centre (MPC) conducts advanced policy-oriented research on global migration, asylum and mobility. It serves governance needs at European and global levels, from developing, implementing and monitoring migration-related policies to assessing their impact on the wider economy and society. Robert Schuman Centre for Advanced Studies The Robert Schuman Centre for Advanced Studies (RSCAS), created in 1992 and directed by Professor Brigid Laffan, aims to develop inter-disci- plinary and comparative research on the major issues facing the process of European integration, European societies and Europe’s place in 21st century global politics. The Centre is home to a large post-doctoral pro- gramme and hosts major research programmes, projects and data sets, in addition to a range of working groups and ad hoc initiatives. The research agenda is organised around a set of core themes and is continuously evolving, reflecting the changing agenda of European integration, the ex- panding membership of the European Union, developments in Europe’s neighbourhood and the wider world. www.eui/rsc The ASILE project Co-funded by thehas received funding from the European Union’s Erasmus+ Programme Horizon 2020 research and innovation programme of under grant the European agreement nº 870787. Union Views expressed in this publication reflect the opinion of individual authors and doi:10.2870/790752 not those of the European University Institute or the European Commission. ISBN:978-92-9084-992-6 © European University Institute, 2021 Content ©Sergio Carrera, Lina Vosyliute, Leiza Brumat and Nikolas Feith Tan ISSN:2467-4540 QM-AX-21-026-EN-N
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