This article includes a statement and answers to separate questions. The questions can be found in this article after the statement.
Statement:
Moniheli ry would like to thank for the opportunity to comment on the Action Plan to prevent racism and promote equality. Moniheli has been involved in the preparation of the Action Plan from its initial preparation, participating in the hearing of experts in the preparation of the Government's statement and commenting on the final Statement. In our previous comments, we have focused on the following points: equality in integration, discrimination in recruitment and the social structures that affect the achievement of equality. In the following, we assess the success of the Action Plan from these perspectives.
- Moniheli has expressed concerns about the impact of the new legislation on integration and admission on the equal rights of migrants in integration processes. The aim is to favour highly qualified professionals among immigrants, and a specific directive will facilitate their process. However, people from all backgrounds will continue to come to Finland. The integration process for these people and the impact of the measures envisaged in the government programme are not addressed in any way in the action plan. These changes include making the integration process the responsibility of the person being integrated, which puts immigrants with no digital or language skills at risk. This group has been supported by associations so far, but cuts in funding for NGOs are putting this support at risk. Inequalities in integration processes contribute to integration failure, exclusion and multidimensional problems, usually at a high cost to society.
- Discrimination against foreign language speakers in recruitment and name-based assumptions about Finnish language skills are commonplace in Finland. The Action Plan takes a stand on equality and non-discrimination in working life. Moniheli calls for more concrete measures aimed at employers and more support for integration seekers in finding employment. Fulfilling the work and earnings obligations associated with citizenship, amidst discriminatory recruitment structures, is otherwise a major problem.
- The government programme, as well as the new legislation on integration, emphasises the implementation of preventive activities in cooperation with the NGO sector. The work done by associations supports equality between individuals by providing complementary services that bring vulnerable individuals closer to the ''norm''. These vulnerable people include immigrants with little knowledge of the Finnish system or who speak a foreign language, people with mental or other health challenges, people with disabilities / autism, people with low digital skills and people suffering from intersectional discrimination. This is not a small group.
If the achievement of equality relies heavily on NGOs, while at the same time making historically large and potentially crippling cuts to the capacity of the sector, Moniheli sees a great risk to the achievement of equality.
Moniheli sees a lot of good in the content of the Action Plan: the issues of the Finnish system have been widely highlighted and feedback and recommendations from the international community have been listened to. It is also good that the lack of fulfilment of the obligation to promote equality is recognised, as well as the aspect of equal opportunities in education. This perspective would also be welcome in the priority area of employment. We also commend the measures taken by the Prime Minister's Office to diversify recruitment. Increasing representation in the state administration is an important step in building trust with the migrant population.
However, the action plan is still very high level. We need to know how its objectives will be implemented in concrete terms. Furthermore, in view of the fact that this is an anti-racism operational programme, there is very little mention of migrants and immigration in the programme. The recognition and understanding of the diversity of society, citizens and religions is an element that we would like to see more of throughout the action plan.
Questions:
Respondents were asked to answer a few separate questions, which are:
1. What kind of stakeholder cooperation should take place during implementation (partners, form and focus of cooperation)?
The cooperation should involve a wide range of different cultures and beliefs. In the fight against racist harassment and violence in particular, it would be essential to involve not only the potential targets of harassment and violence, but also those from whom help is sought in these situations. The lack of communication and dismissive attitudes of help providers, which are constantly emerging in communities, fundamentally undermine trust in the Finnish system and the will of officials. This in turn has a strong impact on the experience of equality. For example, cooperation between the police and multicultural organisations has been identified as an effective way of lowering the threshold for preventive contacts and other communication. This in turn has increased the trust of foreign language communities in the police.
In the preparation of the Government Statement, there was some feedback that some communities were not consulted in the preparation. Moniheli was a spokesperson for a number of different cultures, but stakeholder engagement during implementation should pay attention to the greatest possible diversity of partners. We would be happy to assist in this process of community outreach. When communicating the partnership, it should also be clear what the purpose of the activity is and what participants can contribute.
2. How and in which measures should particular attention be paid to combating intersectional and multiple discrimination?
Immigration policy is currently made from the perspective of securitisation. Immigrants are portrayed as potential criminals whose security threat, for example, leads to an increase in the length of stay required to obtain citizenship. The creation of such images is based on racial discrimination, where the consequences of the actions of individual actors extend to entire groups of people. When such discrimination takes place at the level of government and ministries, the most essential way of combating it, from Moniheli's point of view, would be to start by training the authorities to recognise their own prejudices. Only in this way can the planning and preparation of legislation be based on the confidence that decisions are based on researched information, not on prejudice and threatening images.
We trust that intersectional perspectives are present to some extent in all activities. The draft operational programme makes this understanding sufficiently clear. In the case of specific attention, we would take the perspective of the sector in which intersectionality is least familiar to the people involved. All the other measures are in practice aimed at professionals, except the first: social climate and debate. This is aimed at the population as a whole. We therefore consider it particularly important to take intersectional thinking into account in this set of measures. A national campaign on prejudice, how to identify it and how to deal with it could be a good way to start, and Moniheli is happy to be involved in its implementation.
3. What measures are missing from the Action Plan that you think should be promoted in the framework of the Prime Minister's Statement on Equality?
A clear shortcoming of the Action Plan is the programme of measures to combat Islamophobia. Excellent work is already being done on this in the NGO field, recently for example by Fem-R and Amal ry. Islamophobia needs to be raised to the level of anti-Semitism as a separate programme of action to prevent racist harassment and violence. In the case of Islam, discrimination on the basis of religion is commonly combined with discrimination on the basis of skin colour. It extends beyond Muslims to those perceived to be Muslims. Since Islamophobia has been on the agenda in Finland right up to government level, it would be very important that the government itself should also commit itself to taking action to combat it.
There is also no sanction structure for failure to implement an equality plan. The Equality Ombudsman monitors compliance with the obligation to promote equality, but it is clear that the monitoring and resources allocated to the implementation of the plan are currently insufficient. The Action Plan rightly points out that the implementation of the equality plan is mostly formal and that more than a third of Finnish agencies have not trained their staff on equality issues at all. This needs to be clearly changed and the Prime Minister's Office should promote the prioritisation of the fulfilment of the equality duty at all levels of government.
4. How should the implementation and impact of the objectives of the Action Plan be monitored?
Focus groups made up of target groups from different activities to look at changes in the area could be a useful way of monitoring large-scale change.