Ms Isil Gachet, Executive Secretary to ECRI

Reference: Your Draft text for General Policy Recommendation (N:o 10) on School Education

Dear Ms. Gachet,

The office of the Ombudsman for Minorities in Finland has forwarded us your letter and preliminary draft text of ECRI General Policy Recommendation N:o 10 on combating racism and racial discrimination at school. Thus the Ombudsman for Children in Finland has examined Your draft document and sends You sincerely some comments and suggestions concerning this text.

I would like to inform You that The Ombudsman for Children in Finland promotes the realization of the rights and interests of children at the general decision-making and legislative levels. Ombudsman works in collaboration with other officials, organizations, child research and other interest groups dealing with issues concerning children. One aim is to improve collaboration among all those involved in child policy through better coordination. The office of the Ombudsman for Children in Finland was established 1.9.2005 by law.

Some general comments and suggestions of the Ombudsman for Children in Finland:

Basically the draft of the Recommendation is well-founded, comprehensive and well focused on the action against racism and racial discrimination at school setting. There is a constant need to improve the attitudes of school decision makers, principals, teachers and school children themselves through education in order to implement the proposals of the recommendation in practise.

The draft text does not define the concepts of ”racism” and ”minority groups”. It would be helpful to define that minority group refers to for example racial, ethnical, cultural, religional, language, sexual and other minorities.

Non-govermental organizations and voluntary societes should be taken into attention in the text. They should be encouraged to co-operate with schools and educational systen to promote together tolerance and equality and to strengthen children’s over all learning processes in these issues.

It is important to ensure that the national education policy of each country reflects the values and principles of ECRI draft text. This should be included in the regulation and advise that is given by the state to the local and regional schools. The principles should be implemented and included in syllabuses of the schools. The interaction between international and national level is essential in these issues but the final implementation is secured in the day to day work at schools.

The needs of religious minorities are important to take into attention in the contents of the religious education at school. In Finland for example we ensure all religious minorities receive religious education that takes note of their own religion. This ensures equal possilities and basis to the interreligional dialoque. Therefore it is also important to emphasize that religious discrimination is not allowed to happen based on economical reasons. In these cases these minorities do not receive the religious education they would be entitled to. Religious minorities should be ensured positive freedom of religion.

I would like to draw Your attention to the work of The United Nations Committee on the Rights of the Child. The Committee has for example recommended to Finland on September 2005 that the State party examines the extent to which human rights education is available in schools and ensure that all children are not only taught human rights, but also involved in projects where human rights standards and values are implemented in practice, whether at home, in school, or within the community.

We should be aware that media plays significant role in this field. Media (e.g. news and videos for adults, computer games) can cause violent behavior and also discrimination. Media and game companies should carry their social responsibility as companies and also promote non-violent and tolerant way of living. Both state parties and NGO’s should further dialoque with media companies on these issues.

Some detailed comments and suggestions to the draft:

1. Ensure equal access for all to quality school education, and to this end

Ombudsman for Children in Finland takes approving notice to the principle of the child’s best interests which is written into the draft for example to item 39.

To item 39 should be added ”to ensure that students from minority groups get enough assistance in their learning processes”.

2. Combat racism and racial discrimination at school, and to this end

To item 40 is suggested to insert that ”to ensure that race, religion and ethical background is accepted in daily school system in terms of food, practice of religion and dressing”.

To item 41 could be written also ”by ensuring that pupils are given religious education which recognizes their own religious identity which is the basis for inter-religious dialogue and shows due regard for the plurality of their beliefs”.

Yours sincerely,

Maria Kaisa Aula

Ombudsman for Children in Finland
Johanna Aalto Lawyer


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