Agency Management of Arrangements to Meet Australia's Treaty Obligations
The objective of the audit was to assess the effectiveness of Australia’s arrangements to meet its treaty obligations under three selected treaties:
- International Convention on Civil Liability for Bunker Oil Pollution Damage 2001;
- Agreement between Australia and the International Atomic Energy Agency for the Application of Safeguards in connection with the Treaty on the Non-Proliferation of Nuclear Weapons of 1 July 1968 and Additional Protocol; and
- Convention on the Rights of the Child 1990.
1. Australia is a party to around 1990 international treaties of which around two-thirds address matters to do with business and trade, international organisations, health, transport, the environment, and crime. During 2012–13, Australia signed 16 treaties, ratified or acceded to two treaties, amended or accepted amendments to seven treaties and brought 28 treaties into force.
2. A treaty is an international agreement between countries that is governed by international law. The term ‘treaty’ includes a range of recognised international instruments, including charters, conventions, covenants, protocols, agreements, pacts and exchanges of notes or letters. The determining factor on whether an agreement is a treaty is whether the intention is for the countries signing the treaty to be bound by international law. Once in force, a treaty is akin to a domestic contract that is binding and enforceable.1 Treaties must be published and registered with the United Nations (UN).
3. Treaties can be bilateral, between one country and another, or multilateral, between three or more countries or an international body and countries. An example of a bilateral treaty is the Australia-US Free Trade Agreement 2005, while an example of a multilateral treaty is the International Convention for the Regulation of Whaling 1946, to which Australia and 86 other countries are parties.
Australia’s treaty-making framework
4. Traditionally, the making of treaties was the exclusive role of the executive government in Australia. However, in 1996, reforms to the treaty‑making framework were introduced, to provide greater parliamentary scrutiny and consideration of treaties prior to Australia becoming a party to a treaty. The current treaty-making framework includes two phases, the first being treaty negotiation and government approval/signature, followed by parliamentary scrutiny and enactment of legislation to give effect to a treaty (where legislation is required). The framework provides for whole‑of‑government, parliamentary, and state and territory government consultation and consideration of the impact and benefits of a treaty for Australia prior to Australia becoming a party to a treaty. These processes include:
- National Interest Analysis (NIA), to determine the benefits to Australia if it were to become a party to a particular treaty;
- Regulation Impact Statement (RIS), when legislation and/or regulation is required to ratify and implement the treaty;
- legal consideration given to treaty text and proposed legislation, where required;
- consideration of all proposed treaties by the Parliamentary Joint Standing Committee on Treaties (JSCOT);
- briefing and engaging with the state and territory governments through the Standing Committee on Treaties (SCOT), for treaties being negotiated; and
- other mechanisms such as Inter-Departmental Committees, Parliamentary committees, Australian, state and territory government forums or meetings, including the Council of Australian Governments processes on specific issues that include a treaty(s).
5. Once a treaty enters into force for Australia the lead Australian Government agency is responsible for making sure Australia implements the treaty and complies with the relevant obligations. Ongoing visibility for the Parliament and public in relation to the actions taken to implement a treaty’s obligations, and its impact, are influenced by the provisions of the treaty. For example, some treaties include ongoing monitoring and reporting obligations, whereas other treaties do not.
Audit objective, criteria and scope
6. The objective of the audit was to assess the effectiveness of Australia’s arrangements to meet its treaty obligations under three selected treaties. In addressing this objective the audit:
- outlines the framework Australia has put in place to bring treaties into force; and
- assesses whether Australia has arrangements in place to provide assurance that it is fulfilling its international obligations once a treaty enters into force.
7. The three treaties examined by the ANAO, and summarised below, are:
- International Convention on Civil Liability for Bunker Oil Pollution Damage 2001;
- Agreement between Australia and the International Atomic Energy Agency for the Application of Safeguards in connection with the Treaty on the Non‑Proliferation of Nuclear Weapons of 1 July 1968 and Additional Protocol; and
- Convention on the Rights of the Child 1990.
The multilateral International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001 (Bunkers Convention) complements a suite of multilateral International Maritime Organization (IMO) treaties to protect the marine environment from ship‑related oil pollution. The Bunkers Convention establishes a compensation regime for pollution damage from a spill of a ship’s fuel oil, known as bunker oil. The Convention requires all ships of more than 1000 gross tonnes entering an Australian port to hold liability insurance against bunker oil pollution damage and to carry onboard a ‘Bunker Certificate’ confirming their insurance.2
The Bunkers Convention entered into force internationally on 21 November 2008 and was implemented in Australia on 16 June 2009, through the Protection of the Sea (Civil Liability for Bunker Oil Pollution Damage) Act 2008. The Australian Maritime Safety Authority (AMSA) has responsibility for administering the Convention, along with other IMO conventions in relation to maritime safety and protection of the marine environment.
Nuclear Non-Proliferation Treaty
The multilateral Treaty on the Non-Proliferation of Nuclear Weapons 1968 (NPT) is the centrepiece of the international nuclear non-proliferation regime designed to avert the proliferation of nuclear materials and technology that can be used in the development and production of nuclear weapons. The NPT entered into force for Australia in 1973.
The NPT is underpinned by a number of bilateral treaties, between individual countries and the International Atomic Energy Agency (IAEA). Australia’s bilateral treaty with IAEA is the Agreement between Australia and the International Atomic Energy Agency for the Application of Safeguards in connection with the Treaty on the Non-Proliferation of Nuclear Weapons (Comprehensive Safeguards Agreement), which entered into force in 1974, and the Additional Protocol, which entered into force in 1997. The Nuclear Non-Proliferation Act 1987 implements the NPT and the Comprehensive Safeguards Agreement, along with other related nuclear protection and suppression of terrorism conventions. The NPT requires Australia to account for, and report on, all nuclear material and technology in Australia to IAEA.
The Australian Safeguards and Non-Proliferation Office (ASNO), which is located in the Department of Foreign Affairs and Trade (DFAT), is responsible for administering the NPT and Comprehensive Safeguards Agreement, by undertaking the required domestic regulatory activities to make sure that Australia is in compliance with safeguards commitments under the NPT. IAEA also undertakes independent verification and concludes on Australia’s compliance with safeguards commitments under the NPT.
Convention on the Rights of the Child
The multilateral Convention on the Rights of the Child 1990 (CRC) seeks to protect children, promote their well-being and to make sure that they have an appropriate place in society. The CRC recognises the civil, cultural, economic, political and social rights of children. The CRC also aims to protect children from economic exploitation and from performing hazardous work; sexual exploitation; abduction, and the sale of and trafficking of children. The CRC entered into force in Australia in 1991, and includes two optional protocols concerning the sale of children, child prostitution and pornography; and the involvement of children in armed conflict, that Australia ratified in 2007 and 2009 respectively.
The obligations of the CRC are implemented by both Australia’s national, and state and territory governments, under a range of existing legislation and initiatives. Unlike the Bunkers Convention and NPT, there is no specific legislation in place that gives effect to the CRC.
The CRC requires Australia to periodically report to the UN CRC Committee on the Rights of the Child on progress in implementing the CRC. After receiving Australia’s report, the CRC Committee conducts a hearing and then issues concluding observations against Australia’s implementation of the CRC. The Attorney-General’s Department (AGD) is responsible for coordinating and submitting Australia’s report to the CRC Committee, which requires collation of information on the implementation of the CRC from the nine jurisdictions, and leading the Australian delegation at the committee hearings.
8. Treaties form an integral part of Australia’s relationships with the global community. The around 1990 treaties to which Australia is a party cover a wide range of subjects and impose a correspondingly wide range of obligations that are enforceable under international law. Consequently, it is important that the Australian Government has appropriate measures in place to assure itself that its treaty obligations are being met.
9. Australia’s treaty-making framework enables parliamentary scrutiny and consideration of proposed treaties in terms of national interests and regulatory impact prior to Australia becoming a party to a treaty. In respect of the three treaties examined by the ANAO, treaty obligations have been implemented effectively, although improvements could be made to strengthen the administrative arrangements supporting these treaties.
10. The approach adopted by AMSA when implementing the Bunkers Convention in 2009 was sound. AMSA has in place a process for accepting applications, verifying ships’ insurance and issuing the Bunker Certificates. The agency has adopted a risk-based approach for selecting ships for inspection, a component of which involves verifying that the ship holds a valid Bunker Certificate. AMSA did not however modify its inspection checklists or systems to support the consistent recording of Certificate inspection results. AMSA advised that since inspections began all ships inspected have held a valid Certificate. However, the lack of accurate records of ship inspection results limits AMSA’s ability to assure itself that all ships inspected held the required Bunker Certificate. During the audit, AMSA advised that it has now put processes in place to record Bunker Certificate inspections.
Nuclear Non-Proliferation Treaty
11. The NPT has been in force for about 40 years, during which time ASNO has developed mature management arrangements and implemented a regulatory regime to account for Australia’s nuclear materials. This regime includes industry self-reporting, supported by an ASNO inspection regime and the reporting of results to IAEA as well as verification activities undertaken by IAEA in Australia. Based on these activities, IAEA has concluded that Australia’s accounting and use of nuclear materials is in accordance with the safeguards obligations of the NPT. There is however room for ASNO to achieve greater transparency and efficiency by implementing a stronger risk-based approach to its inspection regime of nuclear permit holders.
Convention on the Rights of the Child
12. Implementation of the CRC, like other human rights treaties, poses particular challenges, as responsibility for implementation is shared between agencies and jurisdictions across the Australian, state and territory governments. These shared responsibilities place a premium on effective communication, coordination and consultation both when a treaty is being negotiated and when it is implemented. AGD has put in place broadly effective coordination arrangements to obtain the necessary information from Australian, state and territory government stakeholders for inclusion in Australia’s most recent reports to the United Nations CRC Committee. The format and content of these reports also largely complied with the CRC Committee’s reporting guidelines. AGD’s administration of the reporting process could, however, be improved by developing fit for purpose guidance and capturing the experience gained to assist staff coordinating future CRC reports. Investigating options to improve data collection processes as well as consistency in information provided across jurisdictions would also assist in streamlining future CRC reporting obligations. In addition, AGD could make better use of its website to publicise the CRC and Australia’s progress in meeting its obligations.
Australia’s treaty-making framework
13. The treaty-making framework was reformed in Australia in 1996 to provide for an enhanced role for the Australian Parliament in the treaty‑making process. These arrangements are well established, and provide an appropriate focus on treaty implementation issues prior to a treaty entering into force in Australia. However, this audit has highlighted that the current arrangements, which focus on the treaty-making stage, provide little visibility to the Australian Parliament, or the public, as to the effectiveness of the implementation of a treaty once it comes into force, particularly where a treaty does not include ongoing monitoring and reporting obligations. It is timely, therefore, that consideration be given to opportunities to achieve greater external transparency. In this regard, conducting an implementation review of new treaties, and publicising the outcomes of these reviews would be of benefit. It would also be appropriate for the Australian Government to consider options for the cost-effective ongoing reporting of the implementation of key treaties, including that Australia is meeting its treaty obligations.
14. The ANAO has made three recommendations aimed at improving the administration and ongoing monitoring of the three treaties, and other new and existing treaties by the lead agency. The recommendations relate to: strengthening ASNO’s risk-based approach to its inspection of nuclear material permit holders; improving AGD’s coordination of Australia’s reporting obligations under the CRC; and strengthening monitoring and review arrangements to provide assurance that Australia is meeting its treaty obligations.
Key findings by chapter
Bunkers Convention (Chapter 2)
15. AMSA adopted a sound approach to implementing the Bunkers Convention that included: assessing the resources required to administer the Convention; identifying contingency arrangements to address risks; training staff and communicating with industry stakeholders on their obligations under the Convention. A key role for AMSA in implementing the Convention is to assess applications for ships’ Bunker Certificates, including verifying that the ship holds the required insurance. Each Bunker Certificate is valid for 12 months and must be renewed in February each year. The ANAO’s review of the 57 Bunker Certificates issued to ships in 2012, found that procedures were followed and the process appropriately documented, with each ship’s insurance cover verified.
16. AMSA inspects ships in port for compliance with ship navigation, safety and environmental requirements, including verifying that the ship holds a valid Bunker Certificate. The authority adopts a risk-based methodology to identify and prioritise ships for inspection, based on a range of risk factors.3 In 2011–12, AMSA records show that 7802 inspections were undertaken of the 24 539 visits by ships at 79 Australian ports.4
17. In implementing the Bunkers Convention, AMSA integrated its verification obligations into existing inspection activities. However, it did not modify its inspection templates or systems to accommodate the new requirements. The ANAO reviewed a sample of 154 ship inspection records over 2011–12 and found that ship inspection forms did not allow the marine surveyor to consistently record Bunker Certificate inspection results. In the absence of a checkbox for the Bunker Certificate, 76 per cent of the records reviewed contained a mark against another checkbox which relates to a separate convention on requirements for oil tankers to have appropriate insurance in place for oil pollution. However, only 16 per cent of these records made it clear that this entry referred to the Bunker Certificate, limiting AMSA’s ability to provide assurance that ships held a valid Certificate.
Nuclear Non-Proliferation Treaty (Chapter 3)
18. ASNO has developed the Nuclear Accounting and Permit System to enable it to meet IAEA requirements for reporting nuclear material information under the NPT. The system seeks to account for and maintain an inventory of nuclear materials, along with corresponding details and information on use and location. Users of nuclear materials are assessed and issued permits depending on the required use of, or need for the nuclear materials. Permit holders are then required to periodically report on their nuclear material inventory to ASNO in order to keep the Nuclear Accounting and Permit System up to date. As at 30 June 2012 there were 143 current permits, with three new permits issued over the previous 12 months. The ANAO’s review of all permits found that ASNO had issued the permits in accordance with internal guidance and processes, and the required documentation was appropriately recorded.
19. A records management database supports the Nuclear Accounting and Permit System by generating monthly and annual reports. However, the database is unstable, with limited functionality, impacting on ASNO’s ability to effectively meet Australia’s obligations under the NPT.5 DFAT has allocated funds in 2012–13 to replace the database.6
20. During 2011–12, ASNO undertook 13 inspections of permit holders.7 Inspection of permit holders by ASNO involves: verifying the reported physical location, type and quantity of the nuclear materials; checking that the required records are maintained and that security arrangements are appropriate; and confirming that the permit holder understands the requirements of the permit. The ANAO’s review of the documentation for all inspections completed in 2011–12 confirmed that the inspections were appropriately recorded and documented. ASNO advised that the current approach to identifying permit holders for inspection is based on an assessment of the risks presented by individual permit holders, staffing resources and timing factors. However, there was no documentation to support these assessments. Currently, ASNO’s inspection regime does not differentiate between high and low risk permit holders and, as a consequence, ASNO does not target greater inspection effort towards permit holders assessed as higher risk. There would be merit in ASNO strengthening its processes by developing inspection types of differing intensities that are aligned to the assessed risk of each permit holder.
21. The NPT also includes provisions for IAEA to independently verify Australia’s nuclear material inventory by undertaking scheduled and unscheduled inspections of permit holders. During 2011–12, IAEA undertook 10 verification inspections. IAEA verification activities, in conjunction with Australia’s nuclear material inventory reporting, provided the assurance IAEA required to conclude that Australia’s accounting and use of nuclear material inventory is in accordance with the NPT.
Convention on the Rights of the Child (Chapter 4)
22. The CRC requires that signatories report to the CRC Committee on progress in implementing the Convention at five yearly intervals. The reporting cycle involves consideration by the CRC Committee of the written reports submitted by member countries and non-government organisations, on progress in implementing the CRC. The submission of reports is then followed by a hearing conducted by the CRC Committee, where concluding observations are made on the member country’s progress in implementing the CRC. Australia has taken part in three reporting cycles, and has submitted all reports8 required under the CRC since ratification in 1991 and attended three hearings with the CRC Committee. Australia’s most recent reporting cycle concluded in June 2012, following consideration of the fourth periodic report and list of issues report.
23. AGD has put in place arrangements to coordinate Australia’s reports. However, there was only limited documented planning and guidance material available to assist staff. As a consequence, staff relied on corporate knowledge in preparing the CRC reports. Given the long timeframes between reporting cycles, documenting the process and past experience gained in CRC report preparation would be useful for future CRC reporting.
24. AGD engaged directly with Australian Government agencies in seeking input for the fourth periodic report and the list of issues report. In contrast, engagement with the states and territories was undertaken through the Standing Committee on Treaties (SCOT). The SCOT contact officers work with the relevant line agencies at the state and territory government level to obtain the information required. AGD put in place broadly effective arrangements to engage and obtain information from stakeholders to prepare the reports for the fourth periodic reporting cycle. However, the more active process of engaging stakeholders adopted for the list of issues report resulted in better targeted and timely information provision by government stakeholders.
25. Stakeholders advised the ANAO that there are opportunities to more effectively share, and use, information between different levels of government for CRC reporting purposes. The ANAO observed that AGD expended considerable effort to obtain information from government stakeholders that had previously been provided to other Australian Government agencies. There would be benefit in AGD investigating opportunities to streamline the information gathering process and build stronger networks between Australian, state and territory government agencies.
26. The ANAO’s examination of the fourth periodic report and the list of issues report found Australia largely complied with UN reporting guidelines.9 Australia’s reports provided information about child-focused policies and programs, and progress in meeting previous recommendations made by the CRC Committee, allowing progress to be reviewed. There were gaps however in providing the disaggregated statistical data specified in the CRC Committee guidelines as Australia was also unable to report child specific data (on a per unit basis) according to budgetary allocations.10 AGD advised that this information was not available in the required form. There were also data compatibility and quality issues between jurisdictions, as stakeholders did not always conform to national data specification standards. In addition, Australia’s performance in providing reports in a timely manner was mixed, with the fourth periodic report submitted 18 months late and the list of issues report submitted seven weeks late.
27. Australia broadly complies with its obligations in relation to disseminating CRC reports and communicating the CRC to the public. There are initiatives underway to raise awareness of human rights and the CRC. The AGD website could also better represent Australia’s progress in implementing the CRC since ratification. Only the most recent list of issues report and the CRC Committee’s concluding observations report are included on the AGD website. Including additional information, such as Australia’s previous CRC reports and CRC Committee hearing information (Australia’s Opening Statements and the committee’s concluding observation reports), may assist in raising awareness and knowledge of the CRC. This is the approach taken by a number of other signatories to the CRC.
Improving assurance that Australia is meeting its treaty obligations (Chapter 5)
28. Treaties cover a diverse range of issues and impose obligations on Australia, which are enforceable under international law. These obligations can vary from being highly prescriptive, defined and frequently reported, such as for the NPT, to less prescriptive reporting at infrequent intervals as in the case of the CRC or no reporting requirements, like the Bunkers Convention. Ongoing reporting provides insights and assurance about Australia’s performance in meeting its obligations under a particular treaty.
29. Once Australia becomes a party to a treaty, the lead Australian Government agency becomes responsible for making sure that Australia implements the treaty and meets the relevant obligations. Visibility by the Parliament and the public, as to the actions taken to implement a treaty’s obligations, are dependent on the particular features of the treaty itself, including any monitoring and reporting requirements.
30. Greater visibility over the Australian Government meeting its treaty obligations could be achieved by a treaty implementation review, particularly where the treaty has required new or revised business activities. Such a review would provide a valuable assessment for the lead agency and Parliament of how the treaty was implemented and is being administered. It would not however provide ongoing monitoring and reporting of treaty obligations and there would be benefit in exploring further options for lead agencies to provide ongoing assurance to Parliament for key treaties already in force.
31. DFAT maintains a central online treaties database that records the particulars and associated documents for all Australian treaties in force and under negotiation. While the database is a useful resource, the ANAO identified deficiencies in its capacity and data quality.11 In addition, the database does not identify the lead agency for each treaty, and the treaty text and associated documents, such as the National Interest Analysis and Regulation Impact Statement, are only available in a limited (webpage HTML) format that cannot be easily accessed.
Summary of agencies’ responses
32. The proposed audit report was provided to AMSA, ASNO, AGD and DFAT. All agencies provided a formal response to the proposed report and to the recommendations. Agency responses to recommendations are contained in the body of the report following the relevant recommendation. Agencies’ full formal responses are included in the report at Appendix 1.
33. The audited agencies’ summary responses to the audit are provided below.
34. AMSA was pleased to see that the audit resulted in no recommendations that required an AMSA response. Regardless, considering the importance of having adequate compensation available in case of an oil pollution event involving shipping and the improved assurance that a regional approach to ship inspection provides, AMSA has commenced a process with the Asia Pacific Memorandum of Understanding on Port State Control seeking amendments to the Memorandum to explicitly include the Bunkers Convention as well as the Conventions related to pollution compensation for oil tankers as matters for inspection and reporting on.
35. While not directly relevant to Australia’s treaties obligations, AMSA is taking this action after examining our processes during the audit and recognising that there were further opportunities for improvement not only for Australia but other countries in the region. Should these amendments be accepted then changes to procedures for inspection and reporting will be made over the next 12 to 18 months.
36. ASNO welcomes the focus of the Australian National Audit Office (ANAO) on the important question of managing compliance with IAEA safeguards obligations under the NPT. IAEA safeguards comprise the various measures such as accounting, reporting, analysis and inspections, applied by states parties and the IAEA to ensure compliance with commitments to use nuclear material and technology solely for peaceful purposes. International confidence in the compliance of each state with these obligations derives from confidence in how IAEA safeguards are applied, so the effective, efficient and transparent management of these commitments by national safeguards authorities, such as ASNO, is paramount.
37. The ANAO report acknowledges that ASNO has in place mature management arrangements and a regulatory regime to account for Australia’s nuclear material, and that the IAEA has concluded that Australia’s accounting and use of nuclear material is in accordance with NPT obligations.
38. AGD accepts Recommendation No.2 in the ANAO report on the Agency Management of Arrangements to Meet Australia’s Treaties Obligations concerning Australia’s reporting under the Convention on the Rights of the Child.
39. The Australian Government implements its treaty obligations in good faith as a matter of law and as a matter of course. Arrangements for monitoring and reporting on treaty implementation are in accordance with any relevant provisions of the treaty in question and with the procedures determined by each implementing agency.
40. DFAT agrees in part with recommendation 3 but is not in a position to finalise its consideration until it has had the opportunity to obtain and consider the views of the many agencies that would be affected by its implementation, including states and territories. Given that responsibility for treaty implementation appropriately rests with the lead agency in each case, it is essential that lead agencies retain the discretion to determine what monitoring and reporting arrangements would work for their respective treaties and would be manageable within resource constraints. Lead agencies are also best placed to assess any potential risks associated with reporting. As lead agency on a number of treaties, DFAT has concerns about resource implications and avoiding duplication of existing reporting mechanisms. DFAT considers a one‑size‑fits‑all approach would be impractical and undesirable.
Agencies responsible for implementing and administering Australia’s obligations under treaties are encouraged to consider these recommendations in light of their own particular treaty responsibilities.
To achieve greater transparency and efficiency under the Nuclear Non‑Proliferation Treaty, the ANAO recommends that ASNO implements a stronger risk based approach to its program of inspections of nuclear permit holders by:
ASNO response: Agreed
To improve the coordination of Australia’s reporting under the UN Convention on the Rights of the Child, the ANAO recommends that, Attorney-General’s Department:
AGD response: Agreed in-principle
To demonstrate how Australia is meeting its treaties obligations, the ANAO recommends that the Department of Foreign Affairs and Trade, in consultation with the Joint Standing Committee on Treaties, and taking into account existing treaty-mandated monitoring and reporting arrangements:
DFAT response: Agreed in-part
 Because treaties are legally binding, they may be the subject of legal action adjudicated both by domestic judicial bodies, and, in some cases, international legal tribunals.
 The Bunkers Convention applies to ships other than oil tankers. Oil pollution damage from oil tankers is covered by three other IMO conventions, which Australia has implemented. These conventions allow for a greater level of compensation due to the greater impact on the marine environment of an oil spill from an oil tanker.
 The risk factors used include: the ship’s age, size and type; number of previous deficiencies; country of registration; classification society; if first Australian inspection; and time since previous inspection.
 AMSA uses four risk categories to assist in targeting ships for inspections, with Priority 1 being the highest risk, and Priority 4 the lowest risk, of non-compliance with requirements.
 The limitations increase the risk of delays to Australia’s submission of reports to IAEA and reports being prone to manual data entry errors.
 In 2010–11, funds were allocated to redevelop the two ASNO databases, including the Nuclear Accounting and Permit System, into a new system. However, due to competing resource requirements in DFAT, the upgrade of ASNO’s databases was placed on hold until 2012–13 and is expected to be completed in 2013–14.
 ASNO intended undertaking two inspections in 2012–13, but these had not commenced at the time of audit fieldwork.
 The six reports submitted by Australia include an initial CRC report, two periodic reports, and a ‘list of issues’ report, along with two initial reports related to the ratification of the two optional protocols.
 To supplement the CRC document, both the UN and the CRC Committee provide guidelines that include specific information and statistical data reporting requirements.
 The gaps in disaggregated data include information on ethnicity, refugees, migrant and internally displaced children, child abuse and neglect and children who are victims of sexual exploitation.
 For example, the search function was poor—returning no results for the ‘Bunkers Convention’ when an alternative search returned more than 50 results.