Response of the Greek League for Women’s Rights to the EU Commission’s public consultation on its initiative «Combating gender-based violence – protecting victims and punishing offenders»

Athens, 12 January 2021

The Greek League for Women’s Rights (GLWR), the first exclusively feminist organisation in Greece, established in 1920, and having always among its priorities the elimination of all forms of violence against women, welcomes the European Commission’s initiative for a proposal of a directive on gender-based violence, and especially domestic violence.
In response to the relevant public consultation, the GLWR states what follows:

  1. The GLWR agrees with the Commission’s observation that “violence against women and especially domestic violence remains common in the EU”. The GLWR also underlines, as the Commission does in its “Initial Impact Assessment”, the significant increase of gender-based violence during the pandemic period and in the context of the restrictive measures. The GLWR adds that violence against women occurs in all fields, including the field of employment where it takes the form of harassment, and it is practiced everywhere, by any means, including through the media and on-line communications of any kind.
  2. In view of the alarming situation observed by the Commission regarding gender violence as well as of the absence of EU legislation aiming at preventing and combating violence against women, the GLWR considers that the adoption of a directive (option 3 of the call for public consultation) is absolutely necessary and urgent, so that this extremely important issue is dealt with in a “holistic” and binding manner, in accordance with the Commission’s terms.
  3. The GLWR also considers that, in view of the above findings and of the justification of the necessity for a directive, as put forward by the Commission, in order for this directive to be effective in sending a clear message, it must explicitly and clearly state its scope and aim. It must thus state, as in the Istanbul Convention, that it aims to prevent and combat violence against women, and not merely gender-based violence, and it must mention indicatively domestic violence and employment-related harassment. As a legal basis for such a holistic Directive, the GLWR encourages the Commission to use Article 83(1) TFEU and to include “violence against women and girls” among EU crimes, thus recognising that it is a particularly serious and dangerous crime which needs to be combatted by all Member States on a common basis. This Directive must include sexual exploitation and on-line VAWG.
  4. GLWR considers as a major step forward the fact that within the Istanbul Convention, prostitution is mentioned as a factor making women and girls vulnerable to violence. Indeed, we recognise prostitution as inherently violent, given that the majority of women in the sex trade have experienced rape, harassment and post-traumatic stress disorder. In order to tackle this form of violence, we call on the European Commission to include sexual exploitation in the scope of this legislative action. Tackling demand is central and that sexual exploitation be defined in accordance with the existing definition of child sexual exploitation.
  5. The GLWR urges the EU to adopt a comprehensive EU action plan against VAWG made of holistic legislative actions, pursuing the EU accession to the Istanbul Convention, the creation of an EU network on prevention and a significant increase in funding.

The GLWR warmly congratulates the Commission on its initiative. We express our thanks for the attention that the Commission will kindly pay to the GLWR’s contribution to the public consultation and we wish a great success of the initiative.

On behalf of the GLWR Board

Irene Fereti
President of the GLWR


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