Guest Author: Ann-Kathrin Grunwald
Ann-Kathrin Grunwald studies Law at the University of Bonn with a special interest in European law, international human rights law, and Asylum law.
According to the United Nations High Commissioner for Refugees, “the right to seek and enjoy asylum does not depend on the mode of arrival to a country. People who wish to apply for asylum should be allowed to do so and they should be made aware of their rights and provided legal assistance”.[1] However, looking at Greece’s border and asylum policy, the reality seems different. Greece is a constant recipient of allegations concerning the violation of human rights of Asylum seekers in detention and at the border. Yet, neither the European Court of Justice (CJEU) nor the European Court of Human Rights (ECtHR) ruled over any alleged human rights violations in Greece. In this blog article, I will discuss that pushbacks are constantly denied by the Greek authorities and thus not effectively prosecuted. Further, it will be thematised that the asylum system in Greece bets on the detention of migrants and asylum seekers whose legal basis lacks accordance with EU law and raises concerns about human rights.
Civil society organisations frequently speak about breaches of EU Law and border authorities’ inhumane treatment of asylum seekers. Several sources, amongst others, the European Network of National Human Rights Institutions (ENNHRI)[2], the Greek Ombudsman[3], Human Rights Watch (HRW)[4], and the European Council on Refugees and Exiles (ECRE)[5] make substantiated allegations that the Greek border authorities continue with their pushback practices in the area of the Evros river.[6] From this premise, I will shortly present why pushbacks are illegal and then discuss the handling of pushbacks by Greek authorities.
Relevant legislation prohibiting pushbacks
Every state must guarantee the treatment of every individual according to human rights standards, regardless of migration status.[7] Art. 33 of the Geneva Convention states that the border protection policies of every state must respect the principle of non-discrimination and non-refoulement. At the EU level, these principles are enshrined by the EU Charter of Fundamental Rights in Art. 18 (Right to asylum), Art. 19 (Prohibition of expulsions), and Art. 47 (Right to an effective remedy). The principle of non-refoulement, implemented in EU Asylum Law under Art. 5 Directive 2008/115/EC, prohibits the removal of an individual when there is at least the possibility that this person might fulfil the requirements for international protection or refugee status. Further, Art. 43(1) of the Asylum Procedures Directive (Directive 2013/32/EU) ensures border procedures by stating that when an asylum application is made at a national border, the border authorities must examine the application at these locations under certain conditions.[8]
Also, the Schengen Borders Code (SBC) respects fundamental rights and observes the EU Charter of Fundamental Rights principles. As an obligation, Member States apply it regarding international protection and non-refoulement.[9] For instance, Art. 6(5) SBC provides entry for third-country nationals authorised on humanitarian grounds or because of international obligations. Only under Art. 14(1) SBC, a third-country national who does not enter on humanitarian grounds should be refused entry to the territories of the Member States. Nonetheless, the refusal of entry should be without prejudice if there is the right to asylum and international protection. In fact, under Art. 14(2) SBC, entry can only be refused after a substantiated decision has been made based on precise reasons[10] for the refusal. The decision should be taken by an authority empowered by national law.
Greece is a Member State of the EU, as such obliged to respect Art. 18, 19, and 47 of the Charter,[11] and is bound by its national legislation to non-refoulement.[12] Art. 20 of Law no. 3907 of 2011 implements Art. 5 of the Directive and ensures the respect of non-refoulement. Additionally, Art. 41(1)(d) of Law no. 3907 of 2011 prohibits the return of a person who is granted international protection or applied for such status. Thus, Greece cannot, by law, forcibly refuse entry to a person requesting asylum without assessing whether or not they need it.[13] On the contrary, the principle to protect the human rights of migrants specifies that every state must ensure that their legislation is in accordance with international human rights law and that their practices “permit all migrants to fully enjoy all their human rights and fundamental freedoms.”[14] Hence, the right to seek asylum must be protected by the border policy of Greece.[15]
The denial by Greek authorities causes a lack of prosecution of pushbacks
Given that pushbacks take place at the Greek border and it is the Hellenic police, including specialised border police forces in charge, who operate under the direction of the Ministry of Citizen Protection in the border regions,[16] it is reasonable to claim that the Greek border governance promotes routinely executed pushback practices.[17] The responsible bodies, such as the Ministry of Migration and Asylum[18] or the Hellenic Police[19], however, neglect these accusations and justify pushbacks as appropriate behaviour to protect the EU’s external borders from illegal immigrants.
“Reacting in denial to substantial pushback allegations shows a pattern, which culminates in a lack of investigation,[20] even if the evidence is based on testimonials of asylum seekers.”
The first example of this is a questionnaire from 2021 of the Special Rapporteur on the human rights of migrants.[21] He reached out to several bodies and institutions to learn about current practices and trends regarding how the human rights of migrants are protected and about current obstacles states face in ensuring access for migrants to international protection to prevent pushbacks.[22] The diverging content of the submissions of different actors in Greece, such as the Hellenic Republic[23], the Greek Council of Refugees (GCR)[24], HumansRights360[25] and the Greek National Commission for Human Rights (GNCHR)[26] illustrates well the controversy concerning pushback practices along the Greek border.
Take, for example, the fourth question:
“Please provide information on any concrete instances of pushbacks, including an analysis on the circumstances of the event.”
The answer of the Greek state should not surprise anyone:
“The Hellenic Police, in the framework of its mandate, during the management of the borders, pays focused attention to the protection of fundamental rights of the persons crossing the borders. International, EU and national legal and administrative framework is implemented, guaranteeing the protection of human life and dignity, without discrimination, while respecting the right to international protection and non-refoulement. (…)”
In comparison, HumanRights360 states in its answer the following:
“Although push-backs have been ruled unlawful under international law, the practice is understood to continue in a methodical and widespread manner along the Evros/Meriç border. (…)”
GCR answers as follows:
“During the previous years there has been consistent allegations of push back practices at the Greek-Turkish land borders of Evros. (…) The practice of the alleged pushbacks has been on the spotlight of national and international organization over the past years, however up today no proper investigation has been taken place by the Greek Authorities. (…)”
A second example is the report of HRW published in February 2022, which contains testimonies of asylum seekers who were pushed back to the region of Evros river.[27] This report was sent to the Hellenic Police Headquarters requesting a statement. Subsequently, Dimitrios Mallios, Major General and Chief of the Aliens & Border Protection Branch of the Hellenic Police Headquarters stated in his answer that the Hellenic Police, with the support of Frontex, acts in full compliance with the Greek law and, therefore, within EU Law when protecting Greek borders.
Reacting in denial to substantial pushback allegations shows a pattern, which culminates in a lack of investigation,[28] even if the evidence is based on testimonials of asylum seekers. In 2020, according to the ENNHRI, a maximum of four pushback cases were investigated by the Hellenic police and the Greek Prosecutor.[29] By contrast, multiple complaints were filed by civil society organisations[30] as well as submitted by the Greek Ombudsman[31], while International Organisations[32] such as the International Organization for Migration[33], the UNHCR[34] or the Commissioner for Human Rights Dunja Mijatović [35] called Greece to investigate the latest pushback allegations. GCR, for instance, filed several complaints and lawsuits[36], amongst other things, to the Supreme Court on pushback incidents in the region of Evros from April to June 2019[37]. Nevertheless, the pre-trial investigation of one of the cases has been dismissed on the grounds that “the Greek Police does not proceed to such refoulement operations to the Turkish coast, having a specific mandate and clear orders to follow the procedures and submit the files to the local prosecutorial offices”.
The Greek government’s unwillingness to address the situation leads to a deficiency of effective investigation, whereas, in addition, the cases investigated are not further prosecuted by the courts. This is the reason why, until this stage, neither national courts[38] nor the ECtHR ruled over an alleged violation of the non-refoulement principle in Greek territory. In comparison, for instance, in Austria[39] and Slovenia[40], the national courts found them guilty of carrying out illegal pushbacks. In the cases of Croatia[41] and Hungary[42] the ECtHR pledged guilty for illegal pushbacks. The question remains when Greece will be held accountable.
Detention
EU legislation on the detention of migrants
According to Art. 6 of the Charta, Art. 8(2) of the revised Reception Conditions Directive (2013/33/EU (RCD)), and Art. 15(1) of the Return Directive (2008/115/EC (RD)), Member States may detain an applicant but only under the premise that alternative measures cannot be applied effectively. This is, for instance, the case in pending removal under the RD.[43] Art. 18 of the Asylum Procedures Directive prohibits the detention of applicants solely because they are an applicant. An exhaustive list of grounds for detention and safeguards for detainees are contained in Directive 2013/33/EU (Reception Conditions Directive (recast)).[44]
“The Greek government’s unwillingness to address the situation leads to a deficiency of effective investigation, whereas, in addition, the cases investigated are not further prosecuted by the courts.”
Greek asylum law is not in line with EU law
In this section, I will question if the new legislation and the practices based on it are in accordance with EU Law. Since January 2020, the legislation[45] based on which migrants can be detained changed and was criticised for undermining the general legal principle that the detention of asylum seekers should be exceptional and only be resorted to when necessary to achieve a legitimate purpose.[46] According to Art. 46 of the International Protection Act (IPA), an asylum seeker shall not be detained for the sole reason of seeking international protection or having entered and/or stayed in the country irregularly. However, people can be detained after they apply for asylum or for the reason to let them apply for asylum from inside detention. Afterwards, they remain detained during their asylum application process, whereby 18 months should not be exceeded. Nevertheless, for people whose application will be rejected as inadmissible and thus should remain in detention for pre-removal facilitation, 18 months more can be added. A person can now stay detained for up to 36 months in total.[47]
The first concern can be raised because of the possible time of detention and its compliance with the obligation of Art. 9 Directive 2013/33/EU. It states, “only for as short a period as possible” and to effectuate asylum procedures with “due diligence”. In practice, the time limit starts when an asylum application is submitted at the competent Regional Asylum Office or Asylum Unit inside the detention facility. Therefore, the time the applicant spends in detention is longer than what is counted as “time in detention”. Further on, delays in the registration of asylum applications are a systematic issue that leads to an increased time of detention[48] and, as a result, does not meet the scope of “due diligence”.
Second, L. 4686/2020 leads to a more formalised manner of detention measurements instead of providing facilities and structures, such as open camps. Therefore, the legislation consolidates detention as a rule rather than an exception, as recommended in (EU) 2017/2338 (see above).[49]
Third, similar to the previous legislation[50], based on Art. 46 IPA, migrants who applied for asylum are allowed to be detained because of, amongst other things, the following[51]:
“(b) in order to determine those elements on which the application for international protection is based which could not be obtained otherwise, in particular when there is a risk of absconding of the applicant;
[…]
(d) when he or she constitutes a danger for national security or public order;
(e) when there is a serious risk of absconding of the applicant, in order to ensure the enforcement of a transfer decision according to the Dublin III Regulation.”
“Delays in the registration of asylum applications are a systematic issue that leads to an increased time of detention[52] and, as a result, does not meet the scope of “due diligence”.”
The “risk for absconding” (here referred to in b) and e)), which is defined in Art. 3(7) RD should be based on objective criteria defined by national law. In Greece, however, the relevant provision of national law includes a non-exhaustive list of objective criteria that may be used to determine the existence of such a risk.[53] In Art. 18(g) of Law no. L 3907/2011 is laid out that “objective criteria are – but not limited – to the following subparagraphs ga) – gi)”. However, since the national legislation includes a non-exhaustive and indicative list of such criteria and other criteria are not explicitly defined by law, the national legislation is not in line with the relevant provision of the EU law, providing that said objective criteria “must be defined by law”.[54]
Fourth, as referring to d), the RD does not cover detention on public order grounds, and thus, the relevant Greek provision on pre-removal detention[55] is an incorrect transposition of EU law.[56] As I showed above, the new legislation is partly not in accordance with EU legislation.
Conclusion
To conclude, the alleged pushback practices continue if they have not already become a regular practice. Instead of an adequate method of receiving an application upon arrival, such as by registering each person in accordance with the law, people are pushed out when they attempt to enter the territory. They are, therefore, unable to register their asylum application.[57] The impossibility of prosecuting pushback allegations and bringing the cases to court raises concerns about the interests and independence of the Greek prosecutors and courts. The constant denial of pushback practices by the responsible authorities and the Greek state complicates the proper investigation – but without investigation, the cases will not be heard in court. Due to the reform of the relevant legislation about detention, one can say that detention became the formalised base, and alternative measurements to detention will not be found or implemented by the new legislation. Whether the new legislation is in accordance with EU Asylum Law is also questionable if not proven that it is not.
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[1] United Nations High Commissioner for Refugees, “News Comment: UNHCR Warns of Increasing Violence and Human Rights Violations at European Borders”, UNHCR, February 21, 2022, https://www.unhcr.org/news/press/2022/2/62137a284/news-comment-unhcr-warns-increasing-violence-human-rights-violations-european.html.
[2] European Network of Human Rights Institutions, “The Human Rights of Migrants at Borders – Regional Report”, 2021, https://ennhri.org/wp-content/uploads/2021/09/The-human-rights-of-migrants-at-borders_Regional-report.pdf, 21.
[3] The Greek Ombudsman, “Alleged Pushbacks to Turkey of Foreign Nationals Who Had Arrived in Greece Seeking International Protection” (Statewatch, 2021), https://www.statewatch.org/media/2325/gr-ombudsman-pushbacks-interim-report-4-21.pdf, 7-9.
[4] Human Rights Watch, “‘Their Faces Were Covered’ Greece’s Use of Migrants as Police Auxiliaries in Pushbacks”, April 2022, https://www.hrw.org/sites/default/files/media_2022/04/greece0422_web_0.pdf, 6.
[5] European Council on Refugees and Exiles, “Reception, Detention and Restriction of Movement at EU External Borders” (Heinrich-Böll-Stiftung European Union, July 2021), https://eu.boell.org/sites/default/files/2021-07/ECRE%20e-paper%202021_FINAL_rev.pdf, 17.
[6] Special Rapporteur on the human rights of migrants, “Report on Means to Address the Human Rights Impact of Pushbacks of Migrants on Land and at Sea” (United Nations General Assembly, A/HRC/47/30, May 2021), undocs.org/A/HRC/47/30, 9.
[7] Ibid, 5.
[8] European Parliamentary Research Service, “Asylum Procedures at the Border – European Implementation Assessment”, November 2020, https://www.europarl.europa.eu/RegData/etudes/STUD/2020/654201/EPRS_STU(2020)654201_EN.pdf, 6.
[9] Regulation (EU) 2016/399 of the European Parliament and of the Council of 9 March 2016 (Schengen Borders Code), para. 36.
[10] Schengen Borders Code Annex V Part B.
[11] European Parliamentary Research Service, “Asylum Procedures at the Border – European Implementation Assessment”, 67.
[12] Art. 20 and 41 of Law no. 3907 of 2011; Art. 21 and 42 of Law 4636/2019.
[13] European Council on Refugees and Exiles, “Reception, Detention and Restriction of Movement at EU External Borders”, 14.
[14] Global Migration Group, “Principles and Guideline Supported by Practical Guidance, on the Human Rights Protection of Migrants in Vulnerable Situations” (Office of the High Commissioner for Human Rights, January 2018), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/PrinciplesAndGuidelines.pdf, 21.
[15] Special Rapporteur on the human rights of migrants, “Report on Means to Address the Human Rights Impact of Pushbacks of Migrants on Land and at Sea”, 5.
[16] Amnesty International, “Greece: Violence, Lies and Pushbacks”, January 2021, https://www.amnesty.nl/content/uploads/2021/06/GREECE-VIOLENCE-LIES-AND-PUSHBACKS-20212306.pdf?x64788, 12.
[17] Special Rapporteur on the human rights of migrants, “Report on Means to Address the Human Rights Impact of Pushbacks of Migrants on Land and at Sea”, 9,18; Special Rapporteur on the human rights of migrants, “Human Rights Violations at International Borders: Trends, Prevention and Accountability” (United Nations General Assembly, A/HRC/50/31, April 2022), undocs.org/A/HRC/50/31, para.32; Greek Council for Refugees, “Country Report: Greece – 2021 Update” (European Council on Refugees and Exiles, May 2022), https://asylumineurope.org/wp-content/uploads/2022/05/AIDA-GR_2021update.pdf, 18.
[18] Hellenic Republic Ministry of Migration & Asylum Press Office, “Response of the Minister for Migration and Asylum Mr. Notis Mitarachi to Publicatiοns That Reiterate Allegations of Pushbacks”, Hellenic Republic Ministry of Migration & Asylum, October 7, 2021, https://migration.gov.gr/en/apantisi-ypoyrgoy-metanasteysis-kai-asyloy-k-noti-mitaraki-se-dimosieymata-poy-epanaferoyn-ischyrismoys-peri-epanaproothiseon/.
[19] Human Rights Watch, “‘Their Faces Were Covered’ Greece’s Use of Migrants as Police Auxiliaries in Pushbacks”, Annex: Response from Hellenic Police Headquarters.
[20] European Network of National Human Rights Institutions, “National Report on the Situation of Human Rights of Migrants at the Borders”, July 2021, http://ennhri.org/wp-content/uploads/2021/07/Greek-National-Report.pdf, 21,24.
[21] United Nations Human Rights Special Procedures, “Questionnaire of the Special Rapporteur on the Human Rights of Migrants: Pushback Practices and Their Impact on the Human Rights of Migrants” (Office of the High Commissioner for Human Rights, 2021), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/pushback/Questionnaire-en.pdf.
[22]Special Rapporteur on the human rights of migrants, “Report on Means to Address the Human Rights Impact of Pushbacks of Migrants on Land and at Sea”, Office of the High Commissioner for Human Rights, 2021, https://www.ohchr.org/en/special-procedures/sr-migrants/report-means-address-human-rights-impact-pushbacks-migrants-land-and-sea.
[23] Hellenic Republic, “Response to the Questionnaire from the Special Rapporteur on the Human Rights of Migrants – Submission of Greece” (Office of the High Commissioner for Human Rights, 2021), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/pushback/GreeceSubmission.pdf.
[24] Greek Council for Refugees, “Submission of Greek Council for Refugees” (Office of the High Commissioner for Human Rights, 2021), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/pushback/GreekCouncilforRefugeesSubmission.pdf.
[25] HumanRights360, “Submission of HumanRights360” (Office of the High Commissioner for Human Rights, 2021), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/pushback/HumanRights360_Submission.pdf.
[26] Greek National Commission for Human Rights, “Contribution by the Greek National Commission for Human Rights (GNCHR) to the UN Special Rapporteur on the Human Rights of Migrants in Reply to the Questionnaire on Pushback Practices and Their Impact on the Human Rights of Migrants” (Office of the High Commissioner for Human Rights, 2021), https://www.ohchr.org/sites/default/files/Documents/Issues/Migration/pushback/NHRINIGreeceGNCHRSubmission.pdf.
[27] Human Rights Watch, “‘Their Faces Were Covered’ Greece’s Use of Migrants as Police Auxiliaries in Pushbacks”.
[28] European Network of National Human Rights Institutions, “National Report on the Situation of Human Rights of Migrants at the Borders”, July 2021, http://ennhri.org/wp-content/uploads/2021/07/Greek-National-Report.pdf, 21,24.
[29] European Network of National Human Rights Institutions, “The Human Rights of Migrants at Borders – Regional Report“,2021, https://ennhri.org/wp-content/uploads/2021/09/The-human-rights-of-migrants-at-borders_Regional-report.pdf, 30.
[30] Greek Council for Refugees, “Complaint on Push-Back Incidents in the Region of Evros during the Months of April-June 2019“, Statewatch, 2019, https://www.statewatch.org/media/documents/news/2019/jul/greek-council-for-refugees-Push-backs%20April-June%202019.pdf; HumanRights360, “International Complaint against Greece’s Violent Pushbacks at the Evros Border“, HumanRights360, October 22, 2021, https://www.humanrights360.org/international-complaint-against-greeces-violent-pushbacks-at-the-evros-border/; Panayote Dimitras, “16 Greek Prosecutors Investigate Ghm Complaint on 147 Pushbacks or Deportations of 7000+ Foreigners”, Racist Crimes Watch, July 13, 2021, https://racistcrimeswatch.wordpress.com/2021/06/04/2-294/.
[31] The Greek Ombudsman, “Alleged Pushbacks to Turkey of Foreign Nationals Who Had Arrived in Greece Seeking International Protection”.
[32] Office of the High Commissioner for Human Rights, “Working Group on Arbitrary Detention: Preliminary Findings from Its Visit to Greece (2 – 13 December 2019)”, Office of the High Commissioner for Human Rights, December 13, 2019, https://www.ohchr.org/en/press-releases/2019/12/working-group-arbitrary-detention-preliminary-findings-its-visit-greece-2-13.
[33] International Organization for Migration, “IOM Alarmed over Reports of Pushbacks from Greece at EU Border with Turkey”, International Organization for Migration, June 2020, https://www.iom.int/news/iom-alarmed-over-reports-pushbacks-greece-eu-border-turkey.
[34] United Nations High Commissioner for Refugees, “UNHCR Calls on Greece to Investigate Pushbacks at Sea and Land Borders with Turkey”, United Nations High Commissioner for Refugees, June 2020, https://www.unhcr.org/news/briefing/2020/6/5ee33a6f4/unhcr-calls-greece-investigate-pushbacks-sea-land-borders-turkey.html.
[35] Commissioner for Human Rights, “Letter to the Ministers for Citizens’ Protection of Greece, for Migration and Asylum of Greece and for Shipping and Island Policy of Greece”, Council of Europe, May 3, 2021, https://rm.coe.int/letter-to-mr-michalis-chrysochoidis-minister-for-citizens-protection-o/1680a256ad.
[36] Greek Council for Refugees, “Submission of Greek Council for Refugees”, answers to questions three and four.
[37] Greek Council for Refugees, “Complaint on Push-Back Incidents in the Region of Evros during the Months of April-June 2019”.
[38] European Network of National Human Rights Institutions, “National Report on the Situation of Human Rights of Migrants at the Borders”, July 2021, http://ennhri.org/wp-content/uploads/2021/07/Greek-National-Report.pdf, 21.
[39] Regional Administrative Court of Styria, Judgment LVwG 20.3-2725/2020-86 of 1 July 2021, available at: https://www.asyl.at/de/info/presseaussendungen/gerichtbestaetigtillegalenpush-back/
[40] Supreme Court Judgment I Up 23/2021 of 9 April 2021.
[41] M. H. v. Croatia, applications Nos. 15670/18 and 43115/18, Judgement of 18 November 2021.
[42] Shazad v. Hungary, application No. 12625/17, Judgement of 8 July 2021.
[43] European Council on Refugees and Exiles, “Reception, Detention and Restriction of Movement at EU External Borders”, 20; European Agency for Asylum, “Asylum Report”, 2022, https://euaa.europa.eu/sites/default/files/publications/2022-06/2022_Asylum_Report_EN.pdf, 177.
[44] Report on the implementation of Article 43 of Directive 2013/32/EU of the European Parliament and of the Council of 26 June 2013 on common procedures for granting and withdrawing international protection, available at: https://www.europarl.europa.eu/doceo/document/A-9-2021-0005_EN.html
[45] L. 4636/2019 – (entry into force on 1.1.2020), further amendments by L.4686/2020 in May 2020.
[46] Commission Recommendation (EU) 2017/2338 of 16 November 2017 establishing a common ‘Return Handbook’ to be used by Member States’ competent authorities when carrying out return-related tasks, OJ L 339, 19.12.2017, p. 66; European Agency for Asylum, “Asylum Report”, 177.
[47] Art. 46(5)(b) IPA.
[48] Greek Council for Refugees, “Country Report: Greece – 2020 Update” (European Council on Refugees and Exiles, June 2021), https://asylumineurope.org/wp-content/uploads/2021/06/AIDA-GR_2020update.pdf, 216.
[49] Ibid. p. 203.
[50] Art. 46(2) L 4375/2016.
[51] Art. 46(3) IPA.
[52] Greek Council for Refugees, “Country Report: Greece – 2020 Update” (European Council on Refugees and Exiles, June 2021), https://asylumineurope.org/wp-content/uploads/2021/06/AIDA-GR_2020update.pdf, 216.
[53] Art. 18(g)(a)-(h) L 3907/2011.
[54] Article 3(7) Directive 2008/115/EC.
[55] Article 30(1)(c) L 3907/2011.
[56] Greek Council for Refugees, “Country Report: Greece – 2020 Update”, 210.
[57] European Parliamentary Research Service, “Asylum Procedures at the Border – European Implementation Assessment”, 41; Greek Council for Refugees, “Country Report: Greece – 2021 Update”, 35.