Culture and Migration.
The right to have rights, the problem of “Dirty Hands,” and the ethics of responsibility.
By: Huib Wursten. Author and consultant
This paper examines the role of governments in implementing immigration policies, the challenges of balancing morality, practical consequences, and accountability. This is done by describing three television moments that triggered the author.
In recent years, immigration has become a pressing issue for many countries worldwide. Governments try to create and implement policies that address the challenges posed by immigration, which often involve complex moral considerations.
Self-evidently several cultural issues play a role. This paper emphasizes the cultural context of the specific type of “the rule of law”. The one that includes human rights”. All European Union countries signed such a “narrow rule of law” (see note1) despite the enormous cultural diversity. Five of the seven cultural policy narratives distinguished worldwide are at work in the EU (see note 2). Because of the complexity, it makes the EU an example of what can be expected to happen globally. That’s why this paper will focus mainly on how the EU copes with migration.
Keywords: immigration, dirty hands, human rights, ethical dilemmas, policy considerations, humanitarian concerns, national interests, dirty hands in immigration, moral choices, accountability, just immigration practices.
-Television triggers 1 and 2. The Tunisia deal and “Dirty hands.”
While listening to the comments made by critics on television about the “Tunisia deal” announced on 16 July 2023, my thought went back to 63 years ago. It was 4 April 1960. I watched “Dirty Hands” with my parents, the play by Jean-Paul Sartre, on one of the two Dutch television channels of that time.
“Dirty Hands” evolves around the idea that individuals must take responsibility for their choices and actions, even in complex and morally ambiguous situations. The play raises questions about the nature of political engagement and the need to compromise when confronted with difficult choices in pursuing a greater political goal. The play’s theme was suddenly very relevant in the way the European Union deals with the “hot” issue of immigration.
This paper will address some of the moral dilemmas involved.
Migration trends. Some insights into the complex dynamics shaping human mobility.
Economic, political, environmental, and technological factors all contribute to the movement of people across borders, highlighting the interconnectedness of global issues. Understanding these trends and their implications is crucial for policymakers, governments, and societies to develop inclusive and sustainable solutions.
Right now, more people have been forced to flee their homes than ever before, with a staggering 110 million individuals displaced worldwide, according to a report released by the United Nations High Commissioner for Refugees (UNHCR Policy note #08 — 2017). This is more than any other time since World War II.
Some definitions and facts.
Immigrants, refugees, and asylum seekers are distinct categories of individuals who relocate to a different country, often due to persecution, conflict, or the pursuit of better opportunities. While there can be some overlap in their circumstances and experiences, the key differences lie in their legal status and the reasons behind their migration. Here’s a breakdown of each term. The 110 million from UNHCR includes refugees, asylum seekers and internally displaced persons.
Immigrants: Immigrants voluntarily move to a different country to establish permanent residence. They usually do so for reasons such as employment opportunities, family reunification, education, or simply seeking a better quality of life. Immigrants typically go through a legal process, such as applying for visas, work permits, or permanent residency, to gain legal status in their destination country. The EU is home to many immigrants from various countries around the world. The exact figures may vary, but in 2021, there were approximately 35 million immigrants residing in the EU member states, representing about 7% of the total population of the EU.
Refugees: Refugees have fled their home countries due to well-founded fears of persecution, violence, or conflict. They seek refuge in another country and are unable or unwilling to return due to the dangers they face. Refugees are protected under international law, notably the 1951 Refugee Convention and its 1967 Protocol, which outline the rights and responsibilities of refugees and the countries that host them. They often receive assistance from international organizations and undergo a formal process to be recognized as refugees, including assessments to determine their eligibility for protection. According to the UN Refugee Agency (UNHCR), by the end of 2020, there were approximately 3.8 million refugees in the EU. The largest number of refugees in the EU often come from countries such as Syria, Afghanistan, and Iraq.
Asylum Seekers: Asylum seekers are individuals who have left their home countries and seek protection in another country as refugees. They apply for asylum upon arrival or shortly after and request legal recognition as refugees. Asylum seekers often need more legal status in the country where they seek asylum as their claims are being evaluated. The process involves providing evidence to support their claims of persecution or fear of persecution based on race, religion, nationality, political opinion, or membership in a particular social group. The host country’s authorities review their cases and decide whether to grant them refugee status and the corresponding protection.
The number of asylum seekers in the EU can vary from year to year based on global events and EU policies. In recent years, there has been some fluctuation in the number of asylum seekers in the EU. In 2020, around 461,000 asylum applications were submitted. Mostly from Syria, Ukraine, and Afghanistan
Coping with illegal immigrants is increasingly an important policy matter. Usually, Immigrants have different reasons, such as employment opportunities, family reunification, education, or simply seeking a better quality of life. Immigrants typically go through a legal process, such as applying for visas, work permits, or permanent residency, to gain legal status in their destination country. Receiving countries usually try to control the flow of immigration. Because of the restrictions, an increasing number of people try to reach the receiving countries illegally. The number of migrants staying, for instance, illegally in the European Union increased by almost 60% in 2022. In that year, EU countries together counted more than one million people without the right to reside there, reports the European statistical office Eurostat. Most illegal migrants live in countries at the EU’s external borders, such as Hungary, Croatia, and Greece, and in large Member States, such as Germany and France.
Coping with illegal immigration
It is clear for an American like Thomas Friedman (Friedman 2023). He is convinced that the reference should be “well-understood self-interest”. He writes: “There is only one way to deal with the waves of migrants who will continue to come America’s way. And that is with a very high wall with a very big gate. How can we maintain a safe haven for the truly persecuted and attract the immigrants we need to thrive in the 21st century — both the high-energy, low-skilled immigrants and the high-IQ risk takers — and ensure that the flow of immigrants into America is happening at a pace consistent with our economic needs and our ability to assimilate those migrants culturally and socially.”
In practice, the approach of receiving countries in fighting illegal immigration is less clear-cut. Sometimes it is even taking a morally doubtful shape.
The UK: Operation Maximise. “Cram them into a shoe box”.
The UK’s “hostile environment” policy, introduced in 2012, has faced criticism for creating a culture of suspicion and fear, particularly among immigrants and minority communities. Critics argue that this policy, aimed at deterring illegal immigration, has led to unintended consequences, such as denying essential services to legal residents and the wrongful targeting of individuals. Enver Solomon (Solomon 2023) writes about “Operation Maximise”, the plan to cram people into absurd room-sharing arrangements: “It is cruelty by design”, the consequence of a significant shift from government ministers to purposefully make conditions for men, women and children seeking asylum in the UK as harsh as possible. A government spokesperson said: “Our Illegal Migration Bill will help to stop the boats by making sure people smugglers and illegal migrants understand that coming to the UK illegally will result in detention and swift removal – only then will they be deterred from making these dangerous journeys in the first place.”
The Zero Tolerance Policy at the US-Mexico Border
In 2018, the United States implemented a controversial immigration policy known as the “Zero Tolerance” policy at the US-Mexico border. Under this policy, adults crossing the border illegally were subject to criminal prosecution, resulting in the separation of families and the detention of children in separate facilities. Reports emerged of overcrowded detention centers, inadequate healthcare, and poor sanitation, raising questions about the ethical treatment of detainees and their basic human rights.
Another issue is the Criminalization of Asylum Seekers: The policy treated asylum seekers as criminals rather than individuals seeking refuge, challenging the moral obligation to protect vulnerable populations fleeing violence or persecution.
Due to public pressure and legal challenges, the policy was eventually reversed. Still, the long-term impact on the affected families and the integrity of the immigration system remains debated.
Detention of Asylum Seekers in Australia
Australia’s immigration policy includes mandatory detention for unauthorized arrivals, including asylum seekers who arrive by boat. The policy aims to deter unauthorized maritime arrivals and prevent human trafficking. The approach is criticized for several reasons:
- Indefinite Detention: Asylum seekers can be detained indefinitely while their refugee claims are being processed, which raises ethical concerns regarding the deprivation of liberty and the mental health impact on detainees.
- Offshore Processing: Australia established offshore processing centers in countries like Nauru and Papua New Guinea, outsourcing the responsibility for processing asylum claims and raising questions about the welfare and human rights of those in these facilities.
- Lack of Transparency: The policy has been criticized for its lack of transparency, limited access to legal representation, and restrictions on media reporting, hindering public scrutiny and accountability.
The EU: Outsourcing external border controls and policies
Critics argue that the EU’s external border controls and procedures, and the outsourcing of asylum processing to non-EU countries, raise serious human rights concerns. The conditions in reception centers, including overcrowding, inadequate healthcare, and limited access to legal representation, have been heavily criticized.
Outsourcing to third countries to deter immigration is what Commission President Ursula von der Leyen calls “innovative” ways to tackle people smugglers and reduce the number of people who drown during risky crossings over dangerous seas.
Ideas like sending migrants away to countries deemed safe such as Rwanda, for which Danish Prime Minister Frederiksen campaigned, copying similar ideas in the UK, were not supported by most member states. Also, a judge ruled in the UK that the ‘Rwanda model’ contradicts British law.
- The Turkey deal.
In 2015 almost 1 million refugees arrived in the European Union, while more than 3,500 tragically lost their lives making the dangerous journey. More than 75% of those coming to Europe had fled conflict and persecution in Syria, Afghanistan, and Iraq. The increase in new arrivals dominated headlines, sparked heated public debate, and began to polarize public opinion. While there was a huge outpouring of support and solidarity from some countries and communities, several populist political parties and movements across Europe also employed strong anti-migrant messages and imagery to further their agendas.
The ‘EU-Turkey deal’ is often used to describe the ‘statement of cooperation’ between EU states and the Turkish Government, signed in March 2016. It agreed on three key points:
- Turkey would take any measures necessary to stop people traveling irregularly from Turkey to the Greek islands.
- Anyone who arrived on the islands irregularly from Turkey could be returned there.
- For every Syrian returned from the islands, EU Member States would accept one Syrian refugee who had waited inside Turkey.
In exchange, Turkey would receive €6 billion to improve the humanitarian situation refugees face in the country, and Turkish nationals would be granted visa-free travel to Europe.
The message was clear: those attempting to reach Greece irregularly would be swiftly returned, while those who waited patiently in Turkey would have the chance to enter.
While the implementation of the EU-Turkey statement may have contributed to the significant reduction in the number of people risking the tricky journey to Greece, the price for those that do make it to the EU has been very high, and the total sent back to Turkey under the deal has been negligible. Seven years since the agreement was implemented, mass returns have not been made from Greece to Turkey. Approximately 32,472 Syrian refugees have been resettled from Turkey to EU Member States under the agreement.
Refugee organizations are critical of agreements in which the EU cooperates with dubious leaders in exchange for money and economic support to limit the arrival of migrants.
But the recent Tunisia deal is seen as the blueprint for the EU migration policy of the future. The Union is ready to give Tunisia 100 million euros to strengthen border security, pick up migrant boats and send people back to their homeland. The agreement with Tunisia also provides for economic cooperation, including generating and exporting sustainable energy. In addition, more Tunisians will have the opportunity to study and work in the EU.
The European Commission expects similar agreements with Egypt, Algeria and Morocco.
Culture, morality, and immigration
Some critical remarks.
Democracy and the rule of law in the EU
In an earlier paper (Wursten, Lanzer,2012), the EU was described as a unique cultural experiment where five of the seven value systems (see Note 2) that can be defined worldwide are working together and developing a common decision-making structure for shared policies. Understanding the EU in the context of the founding principle is crucial. The combination of democracy, the separation of powers, and a rule of law that includes Human Rights. To be accepted as a member, all the nation-states of the EU must adhere to this combination. These elements are inseparable.
Democracy implies that the member-states population has a say in what is happening in their countries. The majority can choose a government that is trusted to implement the preferred policies of such a majority. If the Government is not doing so, the majority can then send the Government away.
The rule of law makes, however, that the majority cannot take away the rights of the minority. These rights are guaranteed. The separation of powers makes that independent judges can force the majority to protect the rights of minorities. To be accepted as a member state of the EU, all countries must sign for this combination and can be held accountable for the consequences. Some recent developments in Poland and Hungary show that it is worthwhile to be continuously alert.
The rule of law and Human Rights. Some of the implications.
- The right to have rights.
Human rights, in theory, belong to every person. But how are these rights guaranteed? Hannah Arendt suggested that one had to be a person and a citizen of a nation-state.
Arendt wrote: “The right to have rights, or the right of every individual to belong to humanity, should be guaranteed by humanity itself,” But, she said, “It is by no means certain whether this is possible.” Any new international mechanism, she wrote, still depended on the willingness of nations to enforce it—to protect the very people who had been rendered unprotected by losing their national affiliations.
Rights need a context, an audience, or a community in which to claim these rights. Rights don’t exist without a political community that grants and guarantees these rights. First, this applies to the citizenship of democratic nation-states with a clear rule of law. This citizenship safeguards the most fundamental right: The right to have rights.
Who guarantees the rights of asylum seekers in the EU?
In the formal setup of the European Union (EU), the rights of asylum seekers are guaranteed by a combination of EU law, international conventions, and national legislation.
The key entities and legal instruments involved are:
- The EU’s main legal framework governing asylum is the Common European Asylum System (CEAS). The CEAS consists of several directives and regulations that establish common standards and procedures for asylum across EU member states. It includes rules on asylum procedures, reception conditions, qualification for international protection, and the Dublin Regulation, which determines the member state responsible for examining an asylum application.
- European Court of Justice (ECJ): The ECJ is the highest court in the EU and plays a vital role in interpreting EU law, including asylum-related legislation. Its decisions and judgments help clarify member states’ rights and obligations concerning asylum seekers and refugees.
- European Asylum Support Office (EASO): EASO is an EU agency responsible for supporting member states in implementing the CEAS and ensuring a harmonized approach to asylum. It provides guidance, expertise, and technical support to improve the quality and consistency of asylum decision-making and reception conditions across the EU.
- European Commission: As the executive body of the EU, the European Commission proposes legislation, monitors the implementation of EU law, and enforces compliance by member states. It plays a significant role in shaping asylum policies and ensuring their adherence to fundamental rights.
- European Council: The European Council consists of the heads of state or government of EU member states. While it does not directly guarantee asylum seekers’ rights, it sets the overall direction and priorities for the EU’s asylum and migration policies. Decisions made by the European Council can significantly impact the rights and protections afforded to asylum seekers.
- While not an EU institution: the European Court of Human Rights (ECHR): ECHR is not an EU institution, but an international body established by the Council of Europe. However, EU member states are signatories to the European Convention on Human Rights (ECHR), which protects the rights of individuals, including asylum seekers, within the jurisdiction of those states. The ECHR adjudicates complaints of human rights violations, including those related to asylum and migration.
- National Legislation: Each EU member state has national legislation and asylum procedures that must comply with EU law and international obligations. National authorities are responsible for implementing and ensuring the protection of the rights of asylum seekers within their territories.
However, while the EU provides a framework for asylum policies, member states have varying levels of adherence to these standards, leading to disparities in the treatment of asylum seekers.
The complication: outsourcing
The difficulty is that the EU countries are not living up to its values but are outsourcing some of the dirty work around migration. The result is what Kochenov and Ganty call the EU lawlessness law: “a steadily evolving system of conscious legal arrangements purposefully aimed at removing any accountability and or enforceable rights claims from the totality of the liminal context when dealing with the racialised ‘other’ attempting to reach European soil from the former colonies of the EU or claim EU law rights, once settled in the Union.”
According to Kochenov and Ganty, this is not an accident. The EU is built this way. The lawlessness law is the result of its design as a space in which those who hold union citizenship have all rights and those who do not have virtually any Kochenov/Ganty highlight three strategies for the use of lawlessness law:
- Informal repatriation and other agreements with mostly formerly colonized third countries, often coupled with development aid and visa facilitation, which have no legal character, are not controlled by any court, and in some cases, are not even made public.
- Then there is the uncontrolled and unaccountable spending of huge piles of money to buy the services of third parties for “migration management”, for whose respect for human dignity and any responsibility can always and easily be denied when things get ugly.
- And finally: Frontex, the European Border and Coast Guard Agency present everywhere, liable nowhere and for nothing, the institutionalized diffusion of responsibility. By the way, help from the EU Courts is not to be expected; on the contrary: The ECJ, with its refusal to exert any control over the EU Turkey Deal, can, according to Kochenov/Ganty, be called one of the architects of EU lawlessness law.
Back to the introduction: the dirty hands.
Immigration often forces policymakers to make morally challenging decisions, which can be framed within the context of the play by Jean-Paul Sartre. “Dirty Hands” revolves around the idea that individuals must take responsibility for their choices and actions, even in complex and morally ambiguous situations. The play raises questions about the nature of political engagement and the need to compromise when confronted with difficult choices in pursuing a greater political goal.
After watching the play on television, I had, as usual, a strong and emotional discussion with my erudite and open-minded father about the question of whether actions can be judged as good or bad without understanding the intent and the motivation behind actions. My father was clear: certain deeds, like knifing people, are always bad. In my puberal hybris, I asked him: is putting a knife in somebody’s chest bad or good.? He fell into the trap I set for him and answered: “Bad, of course”. My reply:” But if the person behind this act is a surgeon operating?” The good sport he was, my father accepted that making dirty hands is inevitable in certain circumstances. But transparency about intent is a necessity. And, very importantly, those making dirty hands should always be accountable for their actions. In the case of the Surgeon, this implied that he needed to prepare for the operation with all the precautions necessary to avoid complications and that he stays accountable when making mistakes.
Applying this to immigration: The most significant consequence is that Member States may not presume the criteria to be met with the mere existence of an agreement between the EU and a third country and general assurances by that country that migrants will be ‘protected by the relevant international standards.
Under well-established human rights norms, states are obliged to carry out a ‘thorough’ assessment of the accessibility and effectiveness of a third country’s asylum system (see: Illias and Ahmed v. Hungary) and may not rely on diplomatic assurances that are not specific and independently monitored (see: Othman v. United Kingdom).
Furthermore, the vision of seeking endlessly to make refugees the responsibility of other states increasingly empowers those few third states willing to play this EU game, often exacerbating and supporting autocratic tendencies therein. The EU increasingly depends on these regimes, which can easily “coercively engineer” migration to extort the EU.
Rise of populism and xenophobia: Immigration policies of the EU have been a topic of political debate, with populist and far-right parties capitalizing on anti-immigration sentiment. Critics argue that these policies have contributed to the rise of xenophobia, nationalism, and anti-European feelings in certain member states. Critics also highlight the difficulties in integrating immigrants into European societies, including language, employment, education, and social cohesion issues. They argue that EU immigration policies should prioritize effective integration programs to ensure the successful inclusion of newcomers.
Ethics of conviction and ethics of responsibility.
The third television trigger in this paper was a discussion between a well-known actor and the politician responsible for immigration in the Netherlands. The politician was analyzing the practical problems of mass immigration. The consequences for housing, financial support, education, and integration. The actor stood up and shouted: “Do you think there is a price cap on acting on human principles?”
What is at stake here?
Of course, immigration policies that involve dirty hands have wide-ranging consequences. These consequences can manifest in various ways, including violating human rights, creating vulnerable populations, and perpetuating social and economic disparities. Governments must be accountable for their actions and decisions, particularly when they involve morally questionable choices. Governments often encounter conflicting moral imperatives. On the one hand, there is a duty to protect national security, uphold the rule of law, and safeguard the interests of citizens. On the other hand, there is an obligation to respect the dignity and rights of migrants, provide humanitarian assistance, and ensure fairness and justice. Finding a balance between morality and practical consequences in immigration policies is a formidable task for governments.
Transparency and legal frameworks are crucial in ensuring that governments are held responsible for the consequences of their immigration policies. Governments need to recognize the consequences of their actions and be held accountable for their decisions. By engaging in informed and ethical discourse, policymakers can work towards more just and sustainable immigration policies that respect the rights and dignity of migrants while addressing the concerns of their citizens.
Many philosophers and ethicists seek to integrate these elements.
One of the ethicists is Max Weber.
In “Politik als Beruf”, Max Weber introduced his famous distinction between two types of ethics:
The “Ethics of conviction”: people act according to principles and tend to disregard potential consequences.
The “Ethics of Responsibility”: people leave aside principles and act according to what they believe will be the likely consequences of those actions.
In the ethics of conviction, one is bound solely to do the morally correct action; if one guides one’s action by an ethics of responsibility, one “… must answer for the foreseeable consequences of [one’s] actions”.
- The EU is a unique development. As we said before in the paper on the Culture and the EU (Wursten, Lanzer 2012), it is a system where countries with very different value backgrounds try to develop a shared future based on democracy and human rights. Like Timothy Garton Ash (Ash, 2023) says: “Europe is a universalist project, or it’s nothing. This is the continent that gave us the modern nation-state, that gave us a global state system, that had centuries of conflict, and that is now trying to find a better way of being a very diverse people and peoples living together well in peace and freedom. It is essential that people with a migration background, people in the second and third generation, should absolutely feel at home in Europe and should not just have equal rights in theory but, in practice—have equal life chances”.
- It is a necessity to emphasize the importance of transparency and accountability in decision-making processes.
- Ensure that immigration policies are developed through open dialogue, considering the views and concerns of various stakeholders, including immigrants themselves.
- Policymakers should be held accountable for the outcomes of their decisions and address any unintended negative consequences.
- Politicians should recognize that it involves legal and economic considerations and social, cultural, and humanitarian aspects. Policymakers and individuals should approach immigration dilemmas with a comprehensive understanding of the various factors involved.
- They should balance competing humanitarian concerns, economic considerations, national security, social integration challenges, cultural diversity, and potential strains on public resources. Applying the ethics of responsibility requires carefully weighing these competing principles to find a balanced approach that considers the interests of immigrants and the host society.
Bi0 Huib Wursten
Huib Wursten, born in 1942, specializes in advising companies and supra-national organizations on managing global teams. Huib graduated from the University of Amsterdam in educational psychology. Huib was co-owner of ITIM International. For over 30 years Huib has supported and advised organizations in correctly assessing intercultural and organizational culture issues and applying the results to create a winning approach.
Huib is the intellectual father of the “mental Images” By observing how the Hofstede dimensions intersect each other, he identified 7 combinations. He published a book about it in 2019: “The 7 Mental Images of National Culture” making it possible to quickly assess most cultures in the world
- The rule of law
In German, this is known as Rechtsstaat; in French, as Etat de Droit.
Two interpretations of “the rule of law” can be identified. They are (a) a broad definition (no democracy and human rights implied) and (b) a narrow definition.
1. The Broad (or formal) definition: The rules should be such that they can enable the control of Government and citizens’ behavior. The content and form of control are not an issue. All over the world, there are countries that can be identified as claiming they have the rule of law in this sense.
2. The Narrow definition however is found in a limited number of countries. Attributes of the broad- and limited definition:
|Broad (or formal) definition||Narrow definition|
|Attributes of the broad definition are:
| The rule of law also encompasses the following:
- The seven Mental Images
Arendt Hannah, The rights of man; what are they? In Modern Review summer 1949, p. 24-37
Ash Timothy (2023) Homelands: A Personal History of Europe Publisher: Bodley Head (2 Mar. 2023) ISBN-10 : 1847926614 ISBN-13 : 978-18479266
European Council on Refugees and Exiles Debunking the “Safe Third County” Myth. POLICY NOTE #08 — 2017
European Court Of Human Rights, Ilias and Ahmed v. Hungary, Application No. 47287/15, 21 November 2019
European Court Of Human Rights, Othman v. United Kingdom App No 8139/09). 17.1.2012
Enver Solomon, 7 jun 2023 Cram them into a shoebox: that’s Britain’s new anti-migrant strategy – and it won’t work.The Guardian
Friedman Thomas L. May 16, 2023. It’s Time for Biden to Out-Trump Trump on Immigration. New York Times
Hofstede, G., Hofstede, G.J., & Minkov, M. (2010). Cultures and Organizations: Software of the.Mind. Berkeley: McGraw-Hill
Kochenov, Dimitry and Ganty, Sarah, EU Lawlessness Law: Europe’s Passport Apartheid From Indifference To Torture and Killing (January 2, 2023). Jean Monnet Working Paper No 2/2022 (NYU Law School), Available: https://ssrn.com/abstract=4316584 or http://dx.doi.org/10.2139/ssrn.4316584
RSA Legal note/ 2021 EU-Turkey deal: 5 Years of Shame Rule of law capture by a Statement Refugee Support Aegean (RSA) Stiftung PRO ASYL e”
Weber Max “Politik als Beruf,” Gesammelte Politische Schriften (Muenchen, 1921),. Originally a speech at Munich University, 1918, published in 1919 by Duncker & Humboldt, Munich.
Wursten Huib (2019). The 7 Mental Images of National Culture Leading and Managing in a globalized world ISBN-10: 1687633347 ISBN-13: 978-1687633347
Wursten Huib, Lanzer Fernando. (2012) The EU: the third great European cultural contribution to the world. http://www.clubofamsterdam.com/contentarticles/86%20Europe/itim%20eu%20report.pdf