ASET’s observations on the National Integration Strategy

On January 15, the National Integration Strategy which describes the government’s proposed policies towards integrating the refugee and migrant populations into Greek society, was published and made available for public consultation. Given that Greece has not followed a specific program for the social integration of this particular population residing in the country, we welcome the specific initiative which replaces that of 2013. However, as a Representative Council for Research and Documentation (ASET) comprised of representatives of immigrant communities operating in Greece and experts on migration, we are concerned with specific parts of the document.

Immigrants currently in Greece do not all have the same needs. According to the latest data published by the Ministry of Migration Policy, nationwide there are currently 551,277 registered immigrants, originating from at least 150 different countries, having entered Greece at different time periods. At the same time, there are quite a number of people for whom there is no data as they are undocumented. Finally, there are recognized beneficiaries of international protection and asylum seekers, some older and others newly arrived. It becomes clear that this diverse range of profiles should also lead to a rationale of adapting policy based on the different needs of each separate profile. Such an adaptation would be even more accurate if it included, in a proportionate manner, the more empowered populations (eg. communities, second generation) as active actors within the mechanisms involved in integrating the less empowered.

For a large percentage of the above populations, acquiring Greek citizenship would be the last step of the process. Access to citizenship should be the crowning achievement of integration policies. The separation of the citizenship directorate from that of immigration policy is reflected in the document as there is not the slightest mention of how the policies described are, for those who choose it, steps towards achieving this goal (of citizenship). At the same time, the Ministry of Interior announces legislative changes that will on the one hand, make the naturalization process even more transparent, on the other hand however, more demanding, especially regarding proof of one fulfilling the essential requirements. Such a reform in essence, presupposes the existence of an infrastructure for learning Greek language and history. Therefore, the integration strategy needs to explicitly include provisions to respond to the needs of those who wish to become Greek citizens.

Such shortcomings demonstrate the need to approach the integration strategy as a tool with a clear target of the full political and social inclusion of immigrants. It is essential to consult with and include the actors involved in real terms with integration (communities, civil society) right from the initial planning process of this strategy. This is how to achieve a strategy, which through two-way social processes, develops common identity and solidarity and strengthens society as a whole. As opposed to presenting dispersed unilateral management programs.

Following are observations for specific parts of the document:

Chapter 3.4 – Strategic goals of the new National Integration Strategy

Regarding the objective: “to facilitate the return to legality for immigrants who are unable to maintain their legal residence status due to the economic crisis, with the ultimate goal of completing their inclusion in Greek society” firstly, we would add “as well as facilitate the return to legality” for the ever increasing number of asylum seekers whose second grade application has been rejected and are therefore deferred to the category of “foreigner without legal documents”. Beyond that, further clarification is needed on the process of becoming documented, because there are several problems with the existing framework (exceptional reasons). Following the process of acquiring legal documents, should be a strategy to promote access to the long-term residence permit which across Europe, is associated with integration. In a memorandum we have already submitted to the Ministry of Migration Policy, we mention specific measures such as:

a) To conduct, through the decentralized administrations and civil society organizations, a nationwide information campaign on the advantages of the long-term resident status.

b) A two year re-enactment of the transitional provisions of the Immigration Code, which foresaw a reduction of the family income requirements for the acquisition of the long-term resident permit.

c) Synching the Immigration Information System with Taxisnet, so that the administration will automatically know if the relevant income conditions are met in order to then proceed with informing the third country national beneficiary.

Regarding the intended language proficiency programs, we observe a lack of prospect towards the continuity of these language lessons even after the end of the particular program. We also wonder whether any form of financial aid is foreseen for those attending the Greek language courses. In addition, since in certain professions (e.g. exclusive nurses) language proficiency is linked to the acquisition of the license to practice the profession, the management of this action should be done in a way that ensures access to this particular group of people. Finally, there is no mention of the need to teach the mother tongue of immigrants/refugees, something of which the national law has stated provisions.

Line of Action 4 –  Promoting access to the labour market

We notice that the integration policies on access to the labour market appear to be primarily directed at the newly arrived populations without much concern for the older. At the same time, not mentioned are the labour rights of these populations. In particular, there are no provisions for the prevention/protection and intervention in respect to the systematic violation of their labour rights (as is the case, for example, in the agricultural sector, cleaning and domestic work, nursing staff, etc.). On the contrary with the statement “An essential precondition for the smooth integration into the labour market of immigrants legally entering Greece is their placement in jobs which are not fully covered by the domestic workforce” succeeds in establishing the existence of two “parallel” labour systems, while what should be proposed is a treatment for this. A treatment however, that explicitly mentions the other actors involved, such as the Ministry of Labour and EFKA (National Healthcare).

Line of Action 5 – Interculturality

Regarding all references to strengthening the institutional role of intercultural mediators, the description of the role of the mediator is not clear. Also, are there any provisions for special cases as well as for changing the legislation on the appointment/recruitment of third-country nationals to public services (as mediators, language teachers, etc.)?

Line of Action 6 – Civic Participation

Regarding the intended “Offering technical support to immigrant associations, facilitating networking, the exchange of best practices, etc.;” a basic need which is not mentioned in the document is logistical support and in particular the provision of space, which has also been a long-standing request of immigrant communities and associations.

Policy measure 6.1 Promoting and facilitating the civic participation of third-country nationals in order to advance their integration into the public life of Greece

The recently voted change in legislation on the Immigrant Integration Councils excludes their ability to operate in medium and small municipalities, while membership majority is now allocated to members of the City Council.

Line of Action 8 – Targeted policies for vulnerable population groups of immigrants and applicants for/beneficiaries of international protection

There is no reference to LGBTQ+ persons.

Policy measure 8.3: Facilitating the integration of people with disabilities

There is no reference to securing the provision of state benefits to third-country nationals suffering from serious illnesses. As is well known and under the conditions of the Organization of Welfare Benefits and Social Solidarity (OPECA), disability allowance is only granted to immigrants who have the specific residence permit for humanitarian reasons. The recently voted legislation, which imposes on third-country nationals with disabilities to choose between integration via labour or via state benefits, must change.

Policy measure 8.4: Facilitating the integration of the elderly

In terms of facilitating the integration of the elderly, there is no reference towards ensuring equal retirement provisions. According to the current institutional framework (v.4387/2016) immigrants as well as naturalized Greek citizens receive a reduced pension despite having the required insurance stamps. This is because the system requires them to prove 40 years of residence in Greece where only the years of legal residence are calculated. This is clearly not feasible, considering that the data processing of residence permits began in 1998. Consequently, this requirement deterministically leads to the unequal treatment based on origin, between pensioners who have paid equal insurance contributions.

Chapter 4.1. Funding Τools

It is worth noting that the actions outlined in the National Strategic Plan for Integration do not include a timetable for implementation, indicators for measuring the outputs and in particular, the financial instrument from which they will be implemented. The term “indicative funding” in no way guarantees the implementation of the proposed actions. What is more, it is limited to references of the contingency funding under the European Asylum, Migration and Integration Fund (AMIF) which is nearing completion. The multiannual program of AMIF has very little absorption and does not require commitment for all the actions described, and the Structural Funds are “heavy” in terms of implementation of funds, thus both are unable to cover these needs. The possible funding of these actions in a subsequent Multiannual Program would mean delayed implementation or even worse cessation of already active actions. The absence of a timeframe makes the integration strategy problematic as the concept of strategic development is planning and programming (time-wise and implementation) as well as an uninterrupted sequence of activities which will facilitate the integration policies. Scattered actions with no implementation plan and no clear funding make the strategic planning unfeasible.