A/HRC/38/18 ICAO, pointed out that most of the input they received was provided by Governments, often with limited input from civil society. 34. There were reports of obstacles relating to the submission of independent contributions from civil society. For example, the High-level Political Forum process, including voluntary national reporting on the Sustainable Development Goals, reportedly did not provide adequate space for civil society submissions and, where provided for, the contributions were allegedly treated with tokenism. 30 35. Public, inclusive consultations at the national level to feed into important regional and international decision-making processes were an effective means of advancing participation. Ireland, for example, had carried out wide-ranging consultations with various civil society actors in advance of its universal periodic reviews in 2011 and 2016, by setting up a website to inform and receive submissions and by advertising in the national media to draw attention to the process. E. Access to information 36. Access to information was a precondition for any meaningful engagement with multilateral organizations and a recognized and indispensable element of freedom of expression, closely linked to the right to public participation. 31 A number of multilateral organizations recognized the criticality of access to information for effective civil society involvement in their work, including in decision-making and policymaking, and had put in place certain procedures and practices for that purpose. The Human Rights Council, in paragraphs 14 (b) and (c) of its resolution 32/31, called on States to strengthen access to information, including through clear laws and policies on the disclosure of information held by public authorities, and to establish the right to request and receive information, subject to internationally recognized restrictions therein. 37. The comprehensive UNEP policy on access to information enabled accredited participants to have access to the same documentation as Member States and any information in its custody, in the absence of a compelling reason for confidentiality in line with the exceptions listed in the policy. To ensure that civil society could monitor and engage fully in the activities related to the Aarhus Convention and the protocol bodies, all official and important unofficial documents were published on the Convention website. Moreover, members of the public could request information, and confidentiality was limited to clearly defined and strictly interpreted exemptions. The policy established a timeline within which information must be provided, and any refusal must be justified. Any refusal could be appealed through the established internal justice mechanism. 38. In general, access to information was limited in regional and international meetings owing to hierarchical and bureaucratic structures, 32 including those of the European Union33. Some corruption review mechanisms (e.g. the Financial Action Task Force, the United Nations Convention against Corruption and the OECD Working Group on Bribery) did not publish any rules on access to information concerning their international meetings. 34 It was suggested that enhanced on-site access to information and proactive disclosure of information should be encouraged in those institutions. 35 The lack of sufficient notice given to civil society could be an impediment to participation. For example, under its procedures, the Inter-American Commission on Human Rights gave one month’s notice for public hearings, which in practice was insufficient for the participation of regional civil society 30 31 32 33 34 35 Centre for Economic and Social Rights, Together 2030. See A/72/350, paras. 9–22. EUROMIL. See “Challenges facing civil society organizations working on human rights in the EU” (European Union Agency for Fundamental Rights, 2018) p. 43. Transparency International. Transparency International listing the United Nations Convention against Corruption, OECD, Mechanism for Follow-Up on the Implementation of the Inter-American Convention against Corruption, and Financial Action Task Force. 11

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