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Appendix: Human Rights Watch Letter to Ministry of Insurance and Social Affairs

September 14, 2004

H.E. Dr. Amina El-Guindi

Minister of Social Affairs

19 al-Maraghli Street

Cairo, Egypt

Your Excellency,

Human Rights Watch is an international nongovernmental organization that monitors human rights developments in over 80 countries. As part of our regular research, Human Rights Watch is currently examining the status and implementation of Egypt’s Law 84/2002.

As part of our research, we faxed your office a letter on July 8, 2004, asking for information on the law and the Ministry’s important role in its implementation. We regret that, to our knowledge, we have not yet received an answer. For your convenience, I have attached a list of the questions from our July 8 letter on the following page.

We wish to ensure that our materials accurately represent the Ministry’s activities on this issue. We would welcome a reply at your earliest possible convenience. In order to reach us in time to be incorporated into our materials, your reply must reach us no later than September 30.

In addition, Ms Miranda Sissons, a consultant for Human Rights Watch, will be in visiting Cairo from September 18 to September 30. I would be most grateful if you or a representative responsible for implementing Law 84/2002 would be able to meet with Ms Sissons on September 27 or 28. Ms Sissons can be contacted on (02) 735 0815. She will contact your office regarding possible meeting arrangements on arrival.

We thank you in advance for your assistance, and assure you that any initiatives HRW takes regarding Law 84/2002 will take account of any information you are able to provide.

Sincerely,

Sarah Leah Whitson

Executive Director

cc Ibrahim El-Toukhy, Director, Central Department for NGOs, Social Affairs Ministry

     H.E. Ambassador Nabil Fahmy, Embassy of Egypt, Washington, DC.


Summary: Information Requested by Human Rights Watch in our letter of July 8, 2004.

1. A list of the organizations that have successfully registered since Law 84/2002 entered into force.

2. A list of organizations that have attempted to register but have been denied permission or ruled ineligible, including specific reasons in each case of refusal.

3. The number of appeals made by NGOs denied registration and their status; how the Complaints Committee established to arbitrate disputes between NGOs and the Ministry has ruled on these appeals, and if the appeals are being or have been considered by any government body.

4. What procedures does the Ministry use to determine when an organization’s activities violate Article 11 of Law 84/2002? In particular, how does the Ministry decide if an organization’s activities are “political”?

5. Have Ministry representatives been monitoring the activities of organizations registered under Law 84/2002? If so, has the Ministry imposed any administrative or disciplinary measures on any registered NGO? If so, please provide the NGO names and the reasons for such measures.

6. Have any organizations have been cited by the Ministry for having received funds from abroad without permission, as per article 17? If so, which?

7. Has the Ministry has objected to members of NGO governing boards (as per article 34). If so, for which organizations did it object, and for what reasons?

8. Has the Ministry denied registration or otherwise penalized any NGO for being linked to an international organization (as per article 16)? If so, which organizations have been penalized?

9. Has the Ministry has dissolved any NGOs, frozen assets, or confiscated property of any NGO (as per article 42). If so, on what grounds?

10. Are any Egyptian civil organizations exempt from registering under the new law?

11. Must organizations that were formerly registered under Law 153 of 1999 re-register under Law 84? Are all organizations that received formal recognition from the Ministry before 2002 required to re-register?

12. It is our understanding that certain organizations (such as the New Woman Foundation and the Egyptian Initiative for Personal Rights) were initially denied registration for “security reasons.” There is, so far as we are aware, no basis in Law 84/2002 for denying an NGO registration on such grounds. Please clarify the reasons why these organizations were initially denied registration.

13. Please explain whether Law 84/2002 provides the Ministry of the Interior with any role in advising or deciding NGO registration.

14. It is our understanding that Civil Watch for Human Rights recently received a letter from the Ministry of Social Affairs that revoked its registration on behalf of the “General Administration for Security.” Is this correct? If so, we would like to know the basis under Law 84/2002 for the role of the “General Administration for Security” and would appreciate if you could clarify the General Administration’s structure and responsibilities.

15. Does the “General Administration of Security” play a formal or informal role in determining whether an NGO may register under Law 84/2002?




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