To:
The Secretary of the National
Council for Prevention and Combating of Domestic Violence
Mr. Rosen Zhelyazkov -
Minister-Prime Minister of
the Republic of Bulgaria
Mr. Georgi Georgiev -
Minister of Justice
LETTER
From:
NGO Coalition "Together Against
Violence"
January 27, 2025
Subject: Position regarding
the selection of candidates for members
of the National Council for Prevention and
Protection from Domestic Violence
According to Art. 6, para. 3, item 10 and para. 4 of the Regulations on the structure, organization and activities of the National Council for Prevention and Protection from Domestic Violence, the composition of the members of the National Council includes four representatives of non-profit legal entities under Art. 6a, para. 5 of the Law on Protection from Domestic Violence, which carry out activities on prevention and protection from domestic violence, elected in accordance with the procedure of Chapter Three for a term of one year, as the nominal composition of the National Council is determined by a decision of the Council of Ministers after the election procedure in accordance with the rules of Chapter Three of the Regulations and includes main and reserve members.
We believe that the selection process for candidates from the quota for members of the National Council for Prevention and Protection from Domestic Violence was carried out in disregard of the principles of publicity and transparency. The application procedure was announced in the period from 02.01.2024 to 07.01.2025, which actually gives only 3 working days for submitting documents, ignoring the weekend of January 4 and 5 (Saturday and Sunday). Therefore, the requirements of Art. 8, para. 3 and 8 of the Regulations were not met.
No efforts were made to publicize the fact that the procedure was about to be carried out. Especially considering the fact that time is needed to prepare the required documentation. This is especially true with regard to the additional requirement, not regulated in the Regulations on the structure, organization and activities of the National Council for Prevention and Protection from Domestic Violence, to provide documents proving the existence of the required experience of at least 2 years in the field of prevention and protection from domestic violence, before the date of submission of the application and proving that at the time of submission of the application the organization is carrying out real activity. In the present case, the lack of predictability has led to the fact that only two organizations have submitted documents, which is extremely insufficient, given the need for expertise, evident from the inclusion of many directly working on the topic in the working groups at a previous stage of the Council's work. The lack of actual, rather than formally stated, transparency is a significant problem. We believe that the above-described situation creates a barrier to the candidacy of non-profit legal entities that carry out activities related to the prevention and protection of domestic violence.
Within the framework of the working groups held during the discussion of the drafts of the new provisions of the Law on Protection from Domestic Violence, special attention was paid to the need for active involvement of non-governmental organizations, as they have the greatest expertise in the field of combating this social problem. Actions are needed to ensure sufficient publicity and transparency of such procedures, as well as to provide a realistic period for preparation, which would enable all interested parties to prepare and submit their applications.
We ask that you reopen, in accordance with the regulations, the procedure for the election of NGO members in order to supplement the four seats in the National Assembly designated for the civil sector.
NGO Coalition "Together Against Violence"
