A/HRC/10/29 (c) General comments made by other relevant stakeholders 349. The Consultative Committee for Human Rights of Luxembourg welcomed the fact that some of the recommendations made to Luxembourg by the Working Group coincided with the recommendations that it had put forward in its written contribution to the review summary report, as well as the recommendations made by regional bodies. This proved that there were still shortcomings in human rights in Luxembourg in a number of areas. For example, on the question of minors in prison, the Consultative Committee continued to be of the view that prison was fundamentally an inappropriate institution for juveniles. That was also being emphasized by the bodies at the Council of Europe. Regarding immigration and international protection, Luxembourg had a national regulation concerning the modalities for implementing decisions for removal from the territory under constraint. The Consultative Committee noted that the measures that Luxembourg had taken were not appropriate to the subject at hand and that a law should cover this kind of matter. It made an urgent appeal to Luxembourg authorities to ratify the relevant international conventions, in particular the Convention on the Rights of Persons with Disabilities, the Optional Protocol to the Convention against Torture and the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families. It encouraged the Government of Luxembourg to follow up on the recommendations made by the Council under the framework of the universal periodic review. It would monitor their implementation as part of its mandate. 350. The Arab Commission for Human Rights welcomed the transparent way in which the delegation of Luxembourg had responded to the recommendations of the Working Group. It recommended that Luxembourg establish an institutional framework and a time frame for the implementation of recommendations and report back thereon to the Council within a year. It stressed that the participation of non-governmental organizations in the universal periodic review process was important. It noted that Luxembourg chaired the United Nations Economic and Social Council and hoped that Luxembourg would play an increasing role in defending the right of civil society to participate in United Nations deliberations. 351. Cercle de recherche sur les droits et les devoirs de la personne humaine welcomed the report on Luxembourg and commented on paragraph 53 thereto, citing the recommendation on the adoption of a comprehensive strategy for the elimination of violence against women with a preventive component. In this regard, it asked if there was already a comprehensive United Nations strategy concerning violence against women and suggested that, if it existed, it could be adopted by Member States. It also asked if such a strategy would be exclusively for Luxembourg. Along the same lines, it noted that the question of violence approached solely from the standpoint of violence against women would constitute discrimination, since violence against men was also a reality around the world. Therefore, it would be desirable for Luxembourg and all countries to elaborate a comprehensive strategy against violence in general with its three components: men, women and children. It mentioned that it was ready to bring its expertise to assist Luxembourg in the development of such a comprehensive strategy. It also supported the recommendation that Luxembourg cooperate with the adoption of the universal declaration on the duties of the person. 352. The International Federation of Action by Christians for the Abolition of Torture and ACAT Luxembourg had taken note of the date of 2010 for the construction of a closed centre for minors in Luxembourg. They saluted remarks made in the Working Group on the detention conditions of minors and requested that Luxembourg take into account concerns regarding children abandoned at borders. They welcomed the comments made by Luxembourg on alternatives to detention, but were concerned about the possible discriminatory implementation of such measures. They advocated alternatives to detention GE.09-17451 141