ANALYSIS OF THE EUROPEAN COMMISSION PROPOSAL FOR NATIONAL INDICATIVE PROGRAMME FOR ARMENIA

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2 DIRECTORATE-GENERAL FOR EXTERNAL POLICIES OF THE UNION DIRECTORATE B POLICY DEPARTMENT BRIEFING NOTE ANALYSIS OF THE EUROPEAN COMMISSION PROPOSAL FOR NATIONAL INDICATIVE PROGRAMME FOR ARMENIA Abstract Against the background of intensified EU-Armenian relations, the National Indicative Programme (NIP) is a coherent tool in its political, economic and social priorities. It is suited to the needs of the country but uneven in its orientations. The amount of EU contribution has indeed increased since it came from 98,4 million for the period to 157,7 million for the period. However, in the institutional sector, the programme barely evokes the matter of the Nagorno-Karabakh conflict, although it is crucial in Armenia for the formation of a democratic state and it is one of the Country Strategy Paper (CSP) priorities. The corruption fight is seen as the strong point of the programme, but there is no indication on its modus operandi against monopolies and the opaque ties between the authorities and their «entrepreneur friends». In the economic sector, the programme recommends the diversification of the Armenian market and evokes the possible launch of negotiations on the signature of a Free Trade Agreement (FTA) once conditions are fulfilled. However, the part allocated in this sector is in the weakest of the three priorities. The NIP has taken into account the normalisation of relationships between Armenia and Turkey although the process remains uncertain because indexed to a very complex strategic and political context. On the social sector, the struggle against poverty, regional development and the communication infrastructures modernization are the three key points of the NIP; yet, all the powers remain concentrated in the hands of central institutions, suspicious towards redistribution of authority, competences and resources to local authorities. EXPO/B/AFET/FWC/ /Lot1/16 JANUARY 2010 PE EN

3 DG EXPO Policy Department This study was requested by the European Parliament's Committee on Foreign Affairs. AUTHOR: Dr, Gaidz MINASSIAN, Researcher, Group of Political Analysis of the Université Paris Ouest, Lecturer at Sciences-Po Paris. Standard briefing carried out within the framework agreement between IRIS and the European Parliament. Ref.: EP/EXPO/B/AFET/FWC/ /Lot1/16 ADMINISTRATOR RESPONSIBLE: SOURANDER Dag Directorate-General for External Policies of the Union Policy Department WIB 06M083 rue Wiertz 60 B-1047 Brussels LINGUISTIC VERSIONS Original: EN ABOUT THE EDITOR Manuscript completed on 25 January 2010 European Parliament, 2010 Printed in Belgium The study is available on the Internet at If you are unable to download the information you require, please request a paper copy by xp-poldep@europarl.europa.eu DISCLAIMER Any opinions expressed in this document are the sole responsibility of the author and do not necessarily represent the official position of the European Parliament. Reproduction and translation, except for commercial purposes, are authorised, provided the source is acknowledged and provided the publisher is given prior notice and supplied with a copy of the publication. ii

4 Analysis of the European Commission proposal for National Indicative Programme for Armenia EXECUTIVE SUMMARY Scope of the briefing: This ad hoc Briefing analyses the coherence of the National Indicative Programme (NIP) ( ) with Armenia's needs within the European Neighbourhood and Partnership Instrument (ENPI). It assesses the level of adequacy between European assistance programmes and current conditions in Armenia. This paper is divided into three parts a political, an economic and a social part, in accordance with the indications of the NIP Each section offers an analysis of the current situation, an enumeration of the priorities and sub-priorities of the European Union and a general assessment. This study concludes with a series of recommendations. Main findings Democratic Structures: the NIP puts too much emphasis on central institutions which are already omnipotent in the country. Support to local development initiatives lack ambition. Resources to fight against corruption are not specified enough. Professionalization of CSOs should be emphasized, especially within the regions. Too little attention is given to the Nagorny-Karabakh conflict, unlike in the CSP , which made it a priority However, as long as this conflict remains unresolved, reforms of the institutions, that of public administration and that of civil rights will remain shaky, incomplete and fragile, because the security issue will always have priority in Armenia. As a consequence, the opened reforms in other sectors might always be incomplete or unfinished in the case of this conflict not being resolved. Trade and investment: once conditions are fulfilled, the launch of negotiations between Armenia and EU in order to sign a FTA accompanied by a liberalization of the visa policy could bring a major change within current practices and the Armenian mentality. The NIP does not focus enough on this economic component, since out of the three priorities, this is the one that has the lowest share of assistance. Armenia, strongly hit by the recession in 2009 will experience one year of convalescence in 2010, which may weaken the country in the implementation of adaptation programs. More than 40% of the funds are allocated to the renovation and modernisation of the socioeconomic sector. However, the lack of social dialogue and the limited resources allocated to this sector may increase already widening disparities, between the authorities and society as well as between a wealthy minority and a large segment of the population considered as poor. The treatment of the problematic Medzamor nuclear plant deserves a certain firmness rather than constant call for its closure before The issue of education cannot be considered as a priority until Armenia launches its reform of its education system. iii

5 DG EXPO Policy Department CONTENTS EXECUTIVE SUMMARY SCOPE OF THE BRIEFING: MAIN FINDINGS III III III 1 INTRODUCTION 1 2 DEMOCRATIC STRUCTURES AND GOOD GOVERNANCE POLITICAL SITUATION NATIONAL INDICATIVE PROGRAMME ASSESSMENT AND RECOMMENDATIONS 2 3 TRADE AND INVESTMENT, REGULATORY ALIGNMENT AND REFORM ECONOMICAL SITUATION NATIONAL INDICATIVE PROGRAMME ASSESSMENT AND RECOMMENDATIONS 5 4 SOCIO-ECONOMIC REFORM AND SUSTAINABLE DEVELOPMENT SOCIAL SITUATION NATIONAL INDICATIVE PROGRAMME ASSESSMENT AND RECOMMENDATIONS 6 BIBLIOGRAPHY 9 iv

6 Analysis of the European Commission proposal for National Indicative Programme for Armenia 1 INTRODUCTION The initial request for this Briefing Paper specifies that the Briefing Paper should examine the underlying reasons for the review of the European Commission (EC) s Country Strategy Papers (CSPs) and National Indicative Programmes (NIPs), evaluate the substance and impact changes, and indicate what other changes the author considers to be taken into account, if any. In responding to this task, we analyse the IP and project its allocation of funding and composition of priorities against Armenia s current situation and specific needs, as identified by the European Neighbourhood Policy Action Plan (ENP AP), the CSP and the NIP. We divide this briefing into a political, economic and social section, thereby following the structure and the priority axes within the NIP. Each section provides an analysis of the current situation, the projects identified by the NIP and an assessment referring to the above-mentioned tasks. Conclusions and recommendations are included in a final section. The NIP under the European Neighbourhood and Partnership Instrument (ENPI) amounts to million, whereby 47 to 55 million are allocated to the Priority Area 1 (Democratic structures and good governance), 31 to 39 million to the Priority Area 2 (Trade and investment, regulatory alignment and reform), 63 to 71 million to the Priority Area 3 (Socio-economic reform and sustainable development). The programme of the NIP is coherent in its priorities and adapted to the country s needs, but uneven in its guidelines. The contributing amount from the European Union has increased from 98,4 millions for the period from 2007 to 2010 to 157,7 millions from the period of 2011 to 2013, which represents an increase of almost 60% of the assistance. 2 DEMOCRATIC STRUCTURES AND GOOD GOVERNANCE 2.1 Political Situation As noted in the Commission s 2009 Progress Report, Armenia has been undergoing a political crisis since the presidential election of 19th February 2008, for which the OSCE estimated that if the election mostly met international standards in the pre-election period and during voting hours, serious challenges to some commitments would emerge after election day. The crisis reached its peak during the confrontations of 1st March and 2nd March, resulting in the killings of ten people, the arrest of over a hundred people, and the introduction of a state of emergency, which lasted until 20th March. Strong pressure came from the international community, especially from the Parliamentary Assembly of the European Council (PACE) which has passed four resolutions (1609 and 1620 in 2008; 1643 and 1677 in 2009) on the running of democratic institutions. Armenia has gradually taken measures to implement these resolutions in order to avoid its voting right at PACE being suspended. The crisis is still not over. Despite appeals from the European Council in favour of the pursuit of democratic reforms, 14 people linked to the 1st March 2008 events are still imprisoned. However, disciplinary measures have been taken at the end of 2009 against the police officers involved in the events of 1st March. The agreement signed on 10th October 2009 between Armenia and Turkey on the establishment of their diplomatic relations has shaken the Armenian political life. The normalisation process gave rise to a government reshuffle, with the departure of the Armenian Revolutionary Federation (ARF). Currently, 1

7 DG EXPO Policy Department the coalition is made up of three governmental parties, the Republican Party, the Prosperous Armenia Party and the Rule of Law Party. The Opposition acts within this division but takes advantage of the unpopularity of the government in power. The Armenian National Congress, led by the ex-president Levon Ter Petrossian challenges the legitimacy of the regime but supports the overall Armenio-Turkish agreement; the ARF accepts President Serge Sarkissian, but condemns however Armeno-Turkish protocols. The indirect election (a direct election of the City Council followed by the Mayor being elected by this Council) of the Mayor of Yeveran in May 2009 won by the regime s candidate has focused on substantive measures to promote media independence, judicial reform (reform of the penal code) and the fight against corruption. Despite these commitments, the dynamics of democratisation is hardly progressing (which is recalled in the Commission s 2009 Progress Report), especially within the field of human rights, tortures, freedom of expression, NGO status, equality between men and women, children s rights. Nevertheless, according to the NIP , progress in the area of democratisation and fundamental freedoms may contribute to the creation of more favourable conditions for resolution of the Nagorny-Karabakh conflict and the consolidation of peace. According to the Commission s 2009 Progress Report, although tensions are still high, some progress was made in the context of its resolution, including six meetings between the Armenian and Azerbaijani presidents in National Indicative Programme In light of the analysis provided by the ENP AP and the CSP, the aims defined in the NIP with regards to the democratic situation correspond to the broad objectives of assisting Armenia in strengthening the democratic structures, the rule of law, the respect for human rights and fundamental freedoms (Priority Areas 1 and 2 and chapters 4.1 and 4.5 of the ENP AP). But also in improving governance and strengthening its administrative capacity to implement the government s reform. The NIP concerns the following key Sub-priorities: democratic institutions, rule of law and reform of the judiciary public administration reform, including local government and e-governance, public finance management, the fight against corruption human rights and fundamental freedom, civil society development 2.3 Assessment and Recommendations The increase in funding for the first Priority area (i.e. in absolute figures million for as compared to 29,52 million for ) is considered to be well justified in light of both challenges faced by Armenia and EU-Armenia relations priorities, which involve going beyond past levels of cooperation to deepen political cooperation and gradual economic integration (ENP CSP, : 6). This process must contribute to strengthening the rule of law and the consolidation of democracy, to developing a modern state and to respecting human rights and fundamental freedom. Such tremendous importance should however be reflected in budget allocation among priorities : the first Priority area allocation is expected to range from 30% to 35% of the budget, as compared to 40% to 45% for the third Priority area and to 30% of the total budget under the previous NIP ( ). This increase (46-55 million ) also demonstrates that European Union wishes to encourage the Armenian authorities to show some political will in the reforms implementation. 2

8 Analysis of the European Commission proposal for National Indicative Programme for Armenia Democratic developments: Political developments since March 2008 highlight the need to strengthen more independent, transparent and stronger democratic institutions. They especially highlight the need to improve a system of check and balances amongst power branches, the conduct of elections, the need to strengthen the capacity of the Ombudsman institution and the Parliament, the need to foster the participation of civil society in the policy progress. Rule of Law: The focus on the quality of administrative services, the independence of justice and the fight against corruption is consistent with the ENP AP and CSP. The budgetary support should enable Armenia to prioritize the reform of justice. However, these measures in favour of the development of the Rule of Law in Armenia require a tight monitoring as internal instability (political crisis) and external instability (Nagomy-Karabakh conflict) can have an impact on the effectiveness of EU aid. A resumption of hostilities between Armenians and Azeris might lead the Armenian authorities to focus on security measures issues at the expense of reforms in the country by reshaping the Government expenses towards military needs. Such process would undoubtedly slow down the rhythm of reform implementation. The outcomes would be immediate on the European programmes in Armenia. Moreover, if the recent and controversial draft law on NGOs which will result in principle in a willingness to promote the emergence of civil society was to be passed, Armenians could be dissuaded to commit themselves into public life and society organization under the burden of administrative constraints. Indeed, Bill authorities refused to grant the term "union" to any NGO. The draft law also requires that NGOs make public financial reports with more detailed requirements, which may financially ruin the smaller organizations. It promotes finally direct interference by the authorities in the functioning of NGOs. The OSCE, in a detailed report, urged the Armenian government to revise its draft by removing non-compliant items to status and functioning of NGOs in Europe (Articles 1, 2, 3 and 6). The time is also opportune to strengthen the support of civil society by allocating more resources to programmes for the defence of the rights of children, women and young people. The independence of the media must be strengthened. Good governance: The measures of the NPI in favour of the decentralization fall into the Armenian modernization process. This investment is totally justified. Nevertheless, local authorities are often called upon to pass through the parties in power networks in order to strengthen their political intermediaries with central institutions. Despite the authorities good intentions in the corruption fight, much remains to be done. To this end, greater attention must be paid to the fight against monopolies, the impotence of the oligarchs and the opaque relationship between politicians and major contractors, as well as to recruitment in public services, including the police and education. The European Union should assist in drafting an outline law on the publication of political leaders incomes, and an other one about the public funding of political parties. Special care should be borne on the need to rejuvenate the central administration people in charge and on the principle of the significant salaries increase in the public service. 3

9 DG EXPO Policy Department 3 TRADE AND INVESTMENT, REGULATORY ALIGNMENT AND REFORM 3.1 Economical Situation Armenia has moved closer towards becoming a functioning market economy despite its isolation and a difficult environment. The country has enjoyed considerable economic growth since the beginning of Real GDP has increased on average by 12,3% per year between 2001 and 2005 (ENP CSP ), followed by 13,3% in 2006, 13,7% in 2007 and 6,8% in However, Armenia has been hit with full force by the 2008 economic and financial crisis. During January-September 2009, the country experienced a 18,3% negative economic growth, the budget deficit reached 5,7% in the first quarter of 2009, and remittances decreased by 30% within the same period. Growth slowed down significantly in the construction, mining and chemical sectors, both being key sectors of a poorly diversified economy, the global crisis has continued to have a serious impact in , as noted by the IMF (Stand-By Arrangement program, SBA). Aid from international agencies ($823 million from IMF, $545 million from the World Bank) and the signing of bilateral agreements ($500 million from Russia) have helped improve Armenia s economy, yet the country s debt has increased to $3.9 billion (State Budget 2010), nearly 50% of GDP (World Bank outlook). In 2008, the foreign debt represented 13% of GDP. Given the impact of the crisis, Armenia has taken measures in order to escape recession. As noted by the Central Bank of Armenia, the country would end 2009 with a 5,5% inflation (8,9% in 2008, Progress Report Armenia 2009) and Armenia would maintain a macroeconomic and financial stability during this year as well as continue the second-generation reforms, which aims to promote transparency and diversification of its economy. With regards to regional cooperation, Armenia is proceeding with its Cross-Border Cooperation (ENP) under the Black Sea Basin Joint Operational Programme (JOP) The Black Sea JOP covers three priorities and a technical assistance component: supporting cross border partnerships for economic and social development based on common resources ; sharing resources and competencies for environmental protection and conservation ; supporting cultural and educational networks for the establishment of a common cultural environment in the Basin. 3.2 National Indicative Programme Concerning trade and investment, in line with Priority Areas 4 and 5 and chapters 4.4, 4.5 and 4.6 of the EU-Armenia ENP Action Plan, the NIP focuses on the prospect of launching negotiations for an EU- Armenia Association Agreement, including the goals of establishing a FTA facilitating the movement of goods and persons and contributing to the stability and security in the region, as foreseen under the Eastern Partnership. The EC assistance may be needed if the prospect of opening of the border with Turkey materializes before 2013, including the coordination with regional programmes. The NIP envisages the following key Sub-priorities: Promoting trade and investment, in particular market and regulatory reform, including in the areas of business environment, taxations and customs; support for preparation of the future FTA with the EU. Sector-specific regulatory reform and strengthening of administrative capacity 4

10 Analysis of the European Commission proposal for National Indicative Programme for Armenia Border management and migration 3.3 Assessment and Recommendations In light of the forthcoming steps in EU-Armenia relations, the amount of funding for the second Priority area is modest (31-39 million, i.e % of the total budget), a smaller proportion than the previous NIP (30% of the NIP), which could slow down implementation of the measures anticipated. Focus on a limited number of sub-priorities is therefore justified. Promotion of trade and investment, support to export diversification are increasingly important in light of both the global recession and the 2008 conflict between Russia and Georgia, which made more urgent the diversification of Armenian trade flows. Overall, regulatory reform has gained a new importance with the perspective of a FTA. This priority is therefore fully consistent with the intensification of EU-Armenia relation through the Eastern Partnership. The question regarding the opening of the frontier between Armenia and Turkey and the prospects that would follow on the relations between Armenia and the European Union are treated with lack of caution, to the extent that the protocols are still not ratified more than three months after their signature. The European Union has mentioned this border opening in the NIP without, however, giving any guideline on a possible programme revision in the event of a diplomatic failure between Armenia and Turkey. The EU should initiate a workshop reuniting Armenians, Turkish and Europeans, aiming at accompanying and Europeanizing the normalization between Armenia and Turkey. This contact group might be set under the European Commission or European Parliament liability. 4 SOCIO-ECONOMIC REFORM AND SUSTAINABLE DEVELOPMENT 4.1 Social Situation The fight against poverty has become one of the government s priorities, the latter being assisted by international agencies. Thanks to these programmes on development, poverty in Armenia has considerably diminished (currently, less than 25%, as noted by NIP ). However, the global crisis of has diminished its encouraging prospects. The recession has affected the most vulnerable populations and poverty rises in rural areas. According to the National Statistical Service of Armenia reports, the country recorded a 6,8% unemployment in January-October 2009, against 6,3% in the same period in There is a risk that Armenia is moving towards a dual society with about 25% of the population below the poverty level and a small segment of the population experiencing rapid upward social mobility. In addition, differences between Yerevan and the rest of the country are stark, the regions, especially rural areas, are in a precarious situation. In 2010 the government will launch reforms in order to curb the shadowed economy and to liberalize hiring and working condition (social dialogue, social inclusion and protection) with the assistance of the International Labour Organisation and its Decent Work Country Programme for Armenia keeps focusing on the upgrading of rural infrastructure. In

11 DG EXPO Policy Department 2009, projects have been launched in order to improve the modernization of infrastructure and solve the isolation issue within public transport and the energy. Nevertheless, its positive effect will not suffice to overcome the social-economic impact of the crisis. Moreover, the application of these development programmes is hit by three types of problems: monopolies and oligopolies, including the sector of competition policy; the lack of political will, including climate change, the environment, the Information Society applications, Audiovisual; the lack of means, like research and innovation activities. Eventually, in December 2009, the President of the Republic launched the reform on universities, aiming at making education the stepping stone of the Armenia of tomorrow, in line with the Bologna principles. The country actively participated in the Tempus programme, but only includes a few students enrolled through Erasmus. Besides, there is a risk that Armenia will be faced with a double speed education. 4.2 National Indicative Programme Concerning social-economic reform, in line with Priority Area 3 and chapters 4.3 and 4.7 of the EU- Armenia ENP Action Plan, the NIP focuses on the reduction of disparities between regions within the country and its internal cohesion, on the investment with the IFI involvement, including sector budget support programmes and on the development of human capital, as foreseen under the Eastern Partnership, increasing the competitiveness of Armenia, contributing to democratic development, social stability and the resolution of conflicts. The NIP envisages the following key Sub-priorities: Regional and rural development Support for the development of infrastructure in the areas of transport, energy, environment, electronic communications Human capital development, including education and science, social services 4.3 Assessment and Recommendations - The volume of funding attributed to Priority area 3 is the most important: million. As this amount is quite high, it means that Armenian authorities must on a sustained pace fully and truly cooperate with the intention of reaching the goals set. - As the integration of Armenia into the European economy is a strategic objective of EU-Armenia relations, this share has steadily increased as, in the NIP , the amount of aid was of 36,36 million, which shows the increasing number of aligned projects to the European system standards of the whole of the socio-economical sectors. However, if the proportion allocated to social problems is increasing (40% in , 40-45% in ), transport, environment, energy still need very special attention within the modernisation programme of the country s infrastructure. - Social-policy and unemployment: The EC Progress Report has identified social policy and active employment policies as two areas on which Armenia has made limited progress on. Considerable efforts must be polarized on the issue of the right to work and the development of unemployment benefits and retirement pensions, with special attention to women. Structural long term unemployment in particular should be further addressed through support for active employment policies. This is line with Armenia s own priorities set out in the List of Actions for 6

12 Analysis of the European Commission proposal for National Indicative Programme for Armenia to ensure the implementation of the ENP EU-Armenia Action Plan. A financial effort also needs to be achieved to benefit the development of social dialogue. - Education: The NIP foresees a considerable effort within the educational sector in order to facilitate the integration of Armenia within the European Higher Education Area and further involvement with the European Research Area, to improve social services. These measures are important, but remain insufficient, due to the General Education Reform Program for the period of which is still to be adopted, as noted by the Progress Report Until the launch of this transformation process probably in 2010 according to the List of Action for to ensure the implementation of ENP EU-Armenia Action Plan the educational system faces serious challenges, especially in the fight against corruption. Recent reports have demonstrated the existence of a strong correlation between the lack of education, long-term unemployment and poverty, as well as of significant gender disparities in education (UNDP, 2008, Anti-Corruption Participatory Monitoring in Health and Education Sectors). Only the success of the reform led by the Armenian authorities and supported by the EU will enable the educational sector to adapt itself to European standards. - As compared to the previous NIP, a stronger emphasis is put on the sector-specific regulatory reform (e.g. in transport, environment and energy). This evolution matches the ENP AP s requirement as well as the evolution of EU-Armenia relations, with the agreement under negotiation in the aviation sector (Armenia is already a member of Eurocontrol) and the planned integration of Armenia in the Energy Community. Nonetheless, the question of the closure of the Medzamor plant before 2016 should be the subject of special emphasis. EC assistance in the protection of environment levels with the greater attention paid by the Armenian authorities to these issues over the past two years and protecting the environment is one of the major challenges faced by the country. - Regarding local communities decentralization must be strongly supported by political (bicameralism) and administrative (urban communities) innovations, in order to modernise rural areas and to promote the redistribution of power from the centre to the outskirts. - Support of the transformation process of social-economic characteristics also merits greater involvement of the European Union in matters of social protection, including the fight against unemployment and social dialogue. More important investments in the social question would strengthen citizenship in Armenia and would also contribute to show a stronger ambition in the program of the European Neighbourhood and Partnership Instrument (ENPI), while generating greater legitimacy in the process of the integration of Armenia into the European Economic Area. - The protection of the environment (the protection of the Lac Sevan and the fight against air pollution), the development of the energy and the strengthening of educational policies (reform and fight against corruption) require further efforts in the harmonization of Armenia to European standards but also in the fight against poverty and unemployment. Dr, Gaidz Minassian is a Researcher at the Group of Political Analysis of the Université Paris Ouest, Lecturer at Sciences-Po Paris. 7

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14 DG EXPO Policy Department BIBLIOGRAPHY EUROPEAN COMMISSION: European Neighbourhood and Parntership Instrument, Country Strategy Paper, Armenia, , Brussels. EUROPEAN COMMISSION: European Neighbourhood and Partnership Instrument, National Indicative Programme, Armenia, , Brussels. COMMISSION (OF THE EUROPEAN COMMUNITIES) 2008: Communication from the Commission to the European Parliament and the Council, Eastern Partnership (COM(2008) 823/4), Brussels. COMMISSION (OF THE EUROPEAN COMMUNITIES) 2009: Commission Staff Working Document accompanying the Communication from the Commission to the European Parliament and the Council, Implementation of the European Neighbourhood Policy in 2008, Progress Report Armenia (SEC(2009) 511/2), Brussels. COMMISSION (OF THE EUROPEAN COMMUNITIES) 2008: Commission Staff Working Document accompanying the Communication from the Commission to the Council and the European Parliament, Implementation of the European Neighbourhood Policy in 2007, Progress Report Armenia (SEC(2008) 392), Brussels. UNITED NATIONS DEVELOPMENT PROGRAM (UNDP) 2009: The Socio-Economic Impact of climate change in the Republic of Armenia. UNITED NATIONS DEVELOPMENT PROGRAM (UNDP) 2008: Anti-Corruption Participatory Monitoring in Health and Education Sectors. LIST OF ACTION FOR To Ensure Implementation of ENP RA-EU Action Plan, Ministry of Economy of the Republic of Armenia, official website, 6 may OSCE-ODIHR, 2009 : Opinion on the Draft Law on Amendements to Law on "Public Organizations" of the Republic of Armenia, Ms Irina Urumova, ODIHR Expert, Warsaw. Opinion-NR: NGO/ARM/149/2009/(MA) 8

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