A/HRC/43/40/Add.1 25. The Special Rapporteur was also concerned about the lack of oversight of various juvenile delinquency residential care institutions and the failure of the staff to detect and report – or their ignorance regarding – the numerous allegations of children becoming victims of commercial sexual exploitation by organized criminal groups or individuals purposefully targeting these institutions. III. Measures to combat and prevent the sale and sexual exploitation of children 26. Bulgaria has achieved significant progress in introducing a comprehensive legislative, policy and institutional framework of child protection. The focus of the child protection system has largely been on the deinstitutionalization of children and the closure of institutions. 27. Despite various positive steps, there is a lack of a comprehensive strategy to tackle effectively the sale and sexual exploitation of children, including their root causes. Challenges that remain include the fragmented development of child protection and administration of child-sensitive justice focusing on prevention, care, rehabilitation and reintegration; insufficient understanding of what constitutes violence against children; a lack of capacity to identify cases of violence; and insufficient cooperation and informationsharing and inadequate follow-up. Other issues are the lack of comprehensive data collection and lack of understanding of the phenomenon and its root causes, compounded by persistent discrimination against marginalized groups, lack of an adequate procedure for identification and referral, poor and prolonged investigations and prosecutions, insufficient cooperation and allocation of necessary budgetary resources, insufficiently trained and remunerated social workers, and poor understanding of the best interests of the child as a primary consideration. A. Legal framework 28. Bulgaria has ratified most of the core international human rights treaties, including the Convention on the Rights of the Child and the Optional Protocol to the Convention on the Rights of the Child on the sale of children, child prostitution and child pornography. It has also ratified the Council of Europe Convention on the Protection of Children against Sexual Exploitation and Sexual Abuse (Lanzarote Convention) and the Council of Europe Convention on Action against Trafficking in Human Beings. Bulgaria has not signed or ratified the Optional Protocol to the Convention on the Rights of the Child on communications procedure. 29. The Special Rapporteur was concerned about the Constitutional Court’s decision No. 13/2018 of 27 July 2018, in which the Court declared the Council of Europe Convention on Preventing and Combating Violence against Women and Domestic Violence (Istanbul Convention) to be incompatible with the Constitution. She observed during her visit that misinterpretation of the term “gender” had given rise to a hostile environment for organizations working on women’s rights and the rights of lesbian, gay, bisexual, transgender and intersex persons, paving the way to homophobia, transphobia and bias against women. The Special Rapporteur was also concerned about the decision of the legislature to amend the Family Allowance Act to link family allowances for children to school attendance, stipulating the circumstances under which monthly family allowances are to be suspended and terminated, including if the child becomes a parent. The European Committee of Social Rights has recently declared these legislative measures to be racially discriminatory, in that the legislation has a disproportionate impact on Roma and on girls.13 30. The Special Rapporteur welcomes the Child Protection Act (2000) and its subsequent amendments (2013), establishing child protection measures in relation to 13 European Committee of Social Rights, Equal Rights Trust v. Bulgaria, Complaint No. 121/2016, Decision on the Merits, 16 October 2018. 7