e) private enterprises polluting and causing ill-health of inhabitants (whether the inhabitants are in state or private housing); f) faith-based philanthropic landlords granting tenancies on condition that tenants undertake religious instruction. 99. The obligation to fulfil requires government to adopt all appropriate measures, including legislative, administrative and budgetary, to ensure the full realisation of the right to a decent home grounded on Te Tiriti. For example, government must provide temporary emergency housing for people who are homeless and also put in place an effective Te Tiriti and human rights-based housing strategy for all. 100. Violations of the obligation to fulfil include: a) failure to implement provisions of Te Tiriti which relate to kāinga; b) failure to prepare a Te Tiriti and human rights-based housing strategy; c) homelessness; d) failure to provide temporary emergency housing for people who are homeless; e) failure to take all reasonable steps towards a housing system, whether private, public or mixed, which ensures a decent affordable home for everyone; f) failure to put in place transparent, effective and accessible accountability arrangements for the right to a decent home grounded on Te Tiriti. 36 Human Rights Commission 101. Conclusion. Obligations and violations highlight the crucial role of constructive accountability in relation to the right to a decent home grounded on Te Tiriti. Constructive accountability - monitoring, review (including independent review) and redress - assesses whether obligations are being kept, violations are occurring and, if appropriate, remedial action is taken (see section 3 and ‘Constructive accountability’). Guideline 19: Central and local government have obligations arising from the right to a decent home grounded on Te Tiriti. The obligation to respect places a responsibility on government to refrain from interfering directly or indirectly with the enjoyment of the right to a decent home grounded on Te Tiriti. The obligation to protect means that government must prevent third parties, such as private landlords, from interfering with the enjoyment of the right to a decent home grounded on Te Tiriti. The obligation to fulfil requires government to adopt all appropriate measures, including legislative, administrative and budgetary, to ensure the full realisation of the right to a decent home grounded on Te Tiriti. Breaches of these obligations may give rise to violations of the right to a decent home grounded on Te Tiriti.