PART 2: Implementation Guidelines for the Regional Action Plan These Guidelines are intended to provide guidance for NHRIs to implement the RAP. They are intended to be as practical as possible, to assist your NHRI in taking steps towards carrying out the actions in the RAP. These Guidelines will focus on the national actions and include eight modules guided by each national action set out above. A. Cross cutting elements: Consultation, Security and Collective Protection i. NHRIs as HRDs NHRIs themselves can, and should be, considered HRDs. Independent NHRIs promote and strive for the protection and realization of human rights and fundamental freedoms at the national level, in line with the definition of a HRD.2 The former UN Special Rapporteur on the situation of HRDs (UNSR on HRDs), Margaret Sekaggya indicated in her annual report that: “[...] national institutions which operate in compliance with the Paris Principles and their members and staff, can be considered as human rights defenders. She is aware that they face important challenges and are exposed to attacks, threats, intimidation and harassment in connection to their human rights activities”.3 Classifying NHRIs as HRDs recognizes the important work they carry out, the particular rights they are entitled and the dangers they face due to their work. This highlights why NHRIs should consider implementing standards on the rights of HRDs not only externally (for people seeking help) but also internally (for the NHRI staff). As is the case with all HRDs, the enjoyment of rights and risks faced will vary. For example, members of the NHRI who work on the ground with victims will likely be more exposed to reprisals than any other staff. Given the link between the NHRI and the government, confrontational governments may try to financially or legislatively restrict a NHRI. In this vein, restrictions to their mandates, attacks on their autonomy and independence, and limitations to their competences are some of the particular risks that NHRIs face.4 Training programmes and protection tools should therefore take into account the particularities of NHRI as HRDs and be adapted to adequately respond to these challenges. As the SR on HRDs indicated: “...members and staff of national institutions should be aware of the risks that their work could entail and should be properly equipped and trained to face such risks. In addition, specific provisions and resources should be made available in order to provide them with adequate protection if needed.”5 ii. Consultation All actions taken in the implementation of these Guidelines will need to be developed and require adaptation for the relevant national contexts. It is fundamental that you act from the ground with the HRDs, their communities and grassroots organisations, all actions at national and international levels need to start from the ground. All of the national actions set out in this guide must be undertaken in consultation with HRDs. Any action for the protection of HRDs must be led by HRDs. Consultation with HRDs must be done in an inclusive manner and must include HRDs in all their diversity (WHRDs, SOGIESC rights HRDs, Indigenous HRDs etc.) and HRDs working across different areas and issues (migrant’s rights, environmental rights, women’s rights). In each national context there are specific groups 2 UN Declaration on HRD, Article 1, https://www.ohchr.org/en/issues/srhrdefenders/pages/declaration.aspx 3 https://undocs.org/en/A/HRC/22/47 para.34 4 https://undocs.org/en/A/HRC/22/47 pars. 27, 40, 59 5 https://undocs.org/en/A/HRC/22/47 par. 83 9