OPEN LETTER
From reputed professors, Jurists, Lawyers in the EU
on the Legal basis of the Directive on combating violence against women and domestic
violence and the article on the offense of rape1

Form to add your signature:https://docs.google.com/forms/d/e/1FAIpQLSdVlOOTsCz7oeJRirfD9Wm4YurpSDXtYyHEORQNDOfJFshGgA/viewform?usp=sf_link
RE: Harmonisation of the crime of rape based on lack of freely given consent that should be partof the new EU Directive on combating violence against women and domestic violence
1. This Open Letter is signed by the signatories of this article, professors, lawyers, and legal experts
on European Union (EU) law, constitutional law and penal law across the EU, and is addressed tothe co-legislators involved in the interinstitutional negotiations on the Proposal for a Directive on
combating violence against women and domestic violence (the Proposed Directive).2 It provides
legal arguments in support of the Proposed Directive, in particular with respect to thecriminalisation of specific forms of violence against women such as rape. The arguments laid downin this Open Letter are in response to the Opinion of the Legal Service of the Council of the EU(the Legal Service Opinion).3
2. At the outset, we recall that the EU aims at promoting gender equality, as set out by Articles 2 and3(3) of the Treaty on the EU4 (TEU), Articles 8 and 10 of the Treaty on the Functioning of the EU5(TFEU) (together, the Treaties) and Article 21 of the EU Charter of Fundamental Rights.6
Furthermore, Declaration No. 19 on Article 8 of the TFEU establishes that combatting “all kinds ofdomestic violence”’ is part of the EU’s general efforts to eliminate inequalities between women andmen and Member States should take all necessary measures to prevent and punish these criminal
acts and to support and protect the victims. The Proposed Directive is the first piece of legislationin the EU that will comprehensively address violence against women and domestic violence. It aims
to ensure a high level of security and the full enjoyment of fundamental rights within the EU,
including the right to equal treatment and non-discrimination between women and men.

1

* Letter initiated by the European Women's Lobby (EWL).

The EWL is particularly grateful to professors Sara De Vido, (Ca' Foscari University, Venice) and Teresa Freixes(Autonomous University of Barcelona) for their advises and support. The EWL is also very grateful to Wilson Sonsini
Goodrich & Rosati (WSGR) and Deirdre Carroll, Laurine Daïnesi Signoret who povided valuable pro bono assistance forthis letter.

2

Proposal for a Directive of the European Parliament and of the Council of 8 March 2022 on combating violence against
women and domestic violence, COM(2022)105, 2022/0066(COD), available at: https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=CELEX%3A52022PC0105.
3
Opinion of the Legal Service of the Council of the European Union of 31 October 2022 (14277/22), available at:https://data.consilium.europa.eu/doc/document/ST-14277-2022-INIT/en/pdf.
4Treaty on the European Union (OJ C 202, 7.6.2016).
5
Treaty on the Functioning of the European Union (OJ C 202, 7.6.2016).
6
Charter of Fundamental Rights of the European Union (OJ C 202, 7.6.2016).

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3. We recall that the EU has acceded to the Council of Europe Convention on preventing andcombating violence against women and domestic violence (the Istanbul Convention), which enteredinto force on 1 October 2023.7 This accession to the Istanbul Convention reaffirms the EU’scommitment to combat all forms of violence against women and Member States expressly
recognised that “violence against women is a manifestation of historically unequal power relations
between women and men, which have led to domination over, and discrimination against, womenby men, the structural nature of violence against women as gender-based violence, and that
violence against women is one of the crucial social mechanisms by which women are forced into asubordinate position compared with men.”8
4. We consider that the legal bases from the Treaties used in the Proposed Directive are appropriate
for its purpose. The Proposed Directive introduces minimum standards on the definition of criminal
offences that disproportionately affect women and that are not sufficiently addressed at national
level.9 This falls within the EU’s competence as per the areas of eurocrime set out in Article 83(1)TFEU relating to trafficking in human beings and sexual exploitation of women and children andcomputer crimes. Article 83(1) TFEU also provides the legal basis concerning the introduction ofminimum rules on the definition of criminal offences and sanctions in the areas of particularly
serious crime with a cross-border dimension resulting from the nature or impact of such offences
or from a special need to combat them on a common basis.
5. We regret the position of the Council of the EU, in which it proposes to delete the harmonised
definition of the crime of rape, based on the lack of freely given consent.10 We support the
Declaration made by Belgium, Italy, Greece and Luxembourg, also supported by Ireland and Spain,
regretting the lack of political ambition with regard to the criminalisation of the offence of rape. 11
As laid down in this Open Letter, deleting the article proposing a harmonised approach to rape
(Article 5 of the Proposed Directive) defeats the purpose of Articles 82 and 83 TFEU and is notconsistent with other European legal instruments.
1) The notion of rape is a form of sexual exploitation pursuant to Article 83(2) TFEU

7

Council of Europe Convention on preventing and combating violence against women and domestic violence, signed in
Istanbul on 11 May 2011, Council of Europe Treaty Series - No. 210, available at: https://rm.coe.int/168008482e.
8
Id., para. 14.
9
Commission Staff Working document:Subsidiarity Grid Accompanying the document Proposal for a Directive on combating
violence against women and domestic violence of 8 March, 2022, SWD(2022) 60 final, available at: https://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2022:0060:FIN:EN:PDF;
Commission Staff Working Document: Impact Assessment Accompanying the document Proposal for a Directive on
combating violence against women and domestic violence of 8 March 2022, SWD(2022) 62 final, available at https://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2022:0062:FIN:EN:PDF;
Commission Staff Working Document: Follow-up to the second opinion of the Regulatory Scrutiny Board and additional
information the document Proposal for a Directive on combating violence against women and domestic violence of 8 March2022 (SWD) 61 final, available at https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=SWD:2022:0061:FIN:EN:PDF;
andCommission’s Directorate-General for Justice and Consumers, Sosa, L., De Vido, S., Criminalisation of gender-based violenceagainst women in European states, including ICT-facilitated violence – A special report, Publications Office, 2021, available
at https://data.europa.eu/doi/10.2838/960650
10
General Approach of the Council of the European Union of 15 June 2023,10717/23, available at:https://data.consilium.europa.eu/doc/document/ST-10717-2023-INIT/en/pdf
11
Joint statement by Belgium, Greece, Italy and Luxembourg for the COREPER and Council minutes on the general approachon the proposal for a directive of the European parliament and the Council on combating violence against women and domestic
violence of 31 May 2023, 9305/23 ADD 1, available at https://data.consilium.europa.eu/doc/document/ST-9305-2023-ADD1/en/pdf#:~:text=Belgium%2C%20Greece%2C%20Italy%20and%20Luxembourg%20strongly%20support%20the%20Euro
pean%20Commission%27s,must%20be%20addressed%20in%20unison.

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6. The criminal offence of rape constitutes a serious crime and one of the most severe attacks on a
person’s physical, psychological and sexual integrity and autonomy. In 2008, the United Nations
Security Council adopted resolution 1820, which noted that "rape and other forms of sexual
violence can constitute war crimes, crimes against humanity or a constitutive act with respect togenocide". From a gender perspective, rape is a crime that is at the very core of the violation of
women’s fundamental rights, systematically committed against women across Europe.
7. The removal of rape from Article 5 of the Proposed Directive is based on an excessively restrictive
interpretation of the notion of sexual exploitation under EU law. The eurocrime of sexual
exploitation of women and children has already been used to criminalise sexual abuse of children
in Directive 2011/93/EU on combatting the sexual abuse and sexual exploitation of children andchild pornography (the Child Sexual Abuse and Sexual Exploitation Directive).12 The expression“sexual exploitation of women and children” can be interpreted as both exploitation and abuse, inlight of the existing legal instruments in force. Rape is exploitative per se, not only when the victim
is a minor, and not under specific cases. A rapist exploits the position of vulnerability of a person,
turns the person into a sexual object, commits an act characterised by a differential power imbalance
and uses the situation to one’s own advantage. The subordinated position given to women in society
exposes women and girls to a higher risk of gender-based violence and sexual violence - avulnerability exploited by abusers.
8. The European Commission has developed a thorough and sound legal analysis to assess the legal
basis of the Proposed Directive, and an extensive feasibility and subsidiarity analysis. As per thisanalysis, rape is a crime recognised in all the EU Member States; however there are significant
differences in terms of protection of victims across Member States. According to the analysis of theEuropean Commission,13 there are at least 13 Member States that do not include “lack of consent”
as the main constituent element of the crime. The latest analysis14 of the Group of Experts on Action
against Violence against Women and Domestic Violence (GREVIO) on the Istanbul Convention
identified important gaps in the implementation of the standards in Article 36 of the Istanbul
Convention, given the different approaches to the criminalisation of rape.15 Specifically, thedefinitions based on the use of force as the main constituent element of the crime do not offer
adequate protection to victims: the requirement of higher thresholds of evidentiary standards ofphysical resistance and a shifting of the focus onto the victim’s behaviour rather than on theaccused’s actions often results in secondary victimisation. A harmonised approach across the EU isfundamental to address this serious crime and ensure the same level of protection to victims: thelack of consent must be the constituent element of the crime of rape. As per the GREVIO analysis,
the approach based on “affirmative consent” “provide(s) clearer rules to parties at risk ofperpetrating or being victims of sexual violence, as well as providing clarity to those charged withinvestigating and prosecuting such cases”. This is in line with the European Commission and, evenmore so, with the European Parliament proposals that included and elaborated on the exact
definition in the Istanbul Convention.

12

Directive 2011/93/EU of the European Parliament and of the Council of 13 December 2011 on combating the sexual abuse
and sexual exploitation of children and child pornography, and replacing Council Framework Decision 2004/68/JHA (OJ L
335, 17.12.2011, p. 1).
13
European Commission Staff Working Document, SWD(2022) 61 final (n 8).
14
4th General Report on GREVIO’s Activities covering the period from January to December 2022, available at:https://rm.coe.int/4th-general-report-on-grevio-s-activities/1680aca199.
15
Id.

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2) Article 5 of the Proposed Directive does not create a precedent for an excessively extensive
interpretation of Article 83(2)9. The inclusion of Article 5 in the Proposed Directive does not create a precedent for an excessively
extensive interpretation of Article 83(2).
10. With regard to the Child Sexual Abuse and Sexual Exploitation Directive, the Legal Service
Opinion states that “the legal basis of ‘sexual exploitation of children’ has been interpreted
somewhat extensively and used in order to establish minimum rules concerning an offence where
the exploitative element is less present but is rather focused on the use of violence as a form of
sexual abuse.”16 Indeed, Art. 3(5)(iii) of this Directive concerns sexual activities with a child“where use is made of coercion, force or threats.” The Legal Service Opinion notes that“[a]dmittedly, such a provision is based on an extensive interpretation of the notion of ‘sexual
exploitation’ as comprising crimes centred on sexual violence, and thus capable of including
rape.”17 The Legal Service Opinion, however, argues that such a provision thereof may be linked
to a presumption that children are vulnerable, which would not be applicable to adults.18 This ismanifestly doubtful, as the Istanbul Convention recitals state that the Member States “[recognise]that women and girls are exposed to a higher risk of gender-based violence than men.”19
11. Thus, there is a precedent applicable to the sexual exploitation of children, which can clearly beapplied mutatis mutandis to the sexual exploitation of women as involving a situation of violence
involving rape.
3) Article 5 does not infringe the principle of non-discrimination
12. The principle of non-discrimination requires equal treatment of situations that are considered as
objectively comparable.20 However, it is well established in the EU legal order and recalled by the
Proposed Directive that there “is a persisting manifestation of structural discrimination against
women, resulting from historically unequal power relations between women and men. It is a formof gender-based violence, which is inflicted primarily on women and girls, by men”. Violenceagainst women is gender-based violence directed against a woman because she is a woman or that
affects women disproportionately. Such violence is rooted in gender inequality being amanifestation of structural discrimination against women. Further, the Preamble of the Istanbul
Convention recognizes that “women and girls are exposed to a higher risk of gender-based violence
than men.” Men and women are not in situations that can be considered objectively comparable.
13. The EU has systematically put in place legislation based on the principle of positive action that
include measures specifically designed to protect women in the recognition that they are objectively
not in a comparable position as men and have traditionally been discriminated against, with the aimof creating a more egalitarian society. For example, the so-called “Women on boards” Directive21

16

Para. 45 of the Legal Service Opinion (n 2).
Id. para. 39.
18
Id., para. 40.
19
Para.14 of the Preamble of the Istanbul Convention (n 6).
20
See, for instance, Articles 10 and 19 TFEU, and Article 21 of the Charter of Fundamental Rights of the EU. See also
judgement of 16 December 2008, Arcelor Atlantique et Lorraine a.o., C-127/07, EU:C:2008:728, para. 23 and the case-law
cited.
21
Directive (EU) 2022/2381 of the European Parliament and of the Council of 23 November 2022 on improving the genderbalance among directors of listed companies and related measures (Text with EEA relevance), available at: https://eurlex.europa.eu/eli/dir/2022/2381/oj.
17

4

adopted in November 2022 and “Work-life balance” Directive22 adopted in June 2019 specificallyaddress an issue of underrepresentation of women respectively on the boards of big companies andon a labour market in the EU. This recognition of comparably different situations is precisely what
underpins the formulation of the eurocrime “sexual exploitation of women and children”, inrecognition of women’s particular vulnerability. This is the very aim of the Istanbul Convention,
which the EU ratified in full compliance with the Treaties and guarantees that minimum criminal
legal standards apply to counter violence against women and domestic violence across the EU.
4) Article 5 does not enhance the risk of litigation on key provisions of the Proposed Directive
14. For the reasons mentioned above, it seems unlikely that, in case of litigation, there would be a riskof annulment of Article 5 of the Proposed Directive. Article 5 of the Proposed Directive relies on
an appropriate legal basis for its purpose (see para. 1 and 2) and complies with the principle of nondiscrimination (see para. 3).
15. In any event, should Article 5 of the Proposed Directive be found to be based on an extensive
interpretation of Article 83(1) TFEU, and should Article 5 of the Proposed Directive be annulled,
this would not jeopardise the validity of the other provisions of the Proposed Directive. Partial
annulment of an Union act is possible if the elements to be annulled can be distinguished from theremainder of the act.23
Conclusion
16. In sum, we consider that there are no legal justifications that impede considering rape offences andsexual violence offences as forms of sexual exploitation. Nothing prevents the EU from proposing
harmonised definitions of a series of offences included in the Istanbul Convention (ratified by the
EU on 28 June 2023 under the concept of “sexual exploitation of women” in Article 83(1)TFEU). Therefore, the offences proposed by the European Commission (rape and female genital
mutilation); and the additional offences proposed by the European Parliament (rape and sexualassault, female and intersex genital mutilation, sexual harassment, forced marriage and forced
sterilisation) can be considered under this umbrella.
17. Taking into account all the above mentioned arguments, we call on the EU decision makers andMember States in the Council to include in the Proposed Directive the definition of the crime ofrape based on the lack of consent, together with this interpretation of sexual exploitation, during thetrialogue negotiations. It is not only legally accurate, but is also fully supported by European
lawyers and academics, together with the broader civil society in Europe (including women’sorganisations).

Signatures:
1.

Sara De Vido, Associate Professor, Specialised on EU law, International Law, Academia, Italy

22

Directive (EU) 2019/1158 of the European Parliament and of the Council of 20 June 2019 on work-life balance for parents
and carers and repealing Council Directive 2010/18/EU, available at:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32019L1158.
23
European Court of Justice (ECJ), Cases 17/74 Transocean Marine Paint Association v Commission [1974] E.C.R. 1063,
para. 21; ECJ Joined Cases C-68-94 and C-30/95 France and Others v Commission [1998] E.C.R. I-1375, paras. 251-259.

5

2. Dr Teresa Freixes, Autonomous University of Barcelona, Specialised on EU law, InternationalLaw, Constitutional law, Academia, Spain
3. Deirdre Carroll Lawyer Private firm Wilson Sonsini Goodrich & Rosati (WSGR), Specialised on
EU Law, Private Law Firm, Belgium
4.
Laurine Daïnesi Signoret Lawyer Private firm Wilson Sonsini Goodrich & Rosati (WSGR),
Specialised on EU Law, Private Law Firm, Belgium
5.

Eva Soms Bach Project manager, NGO- Civil society, Belgium

6. Henriet Baas PhD Researcher, European University Institute, Specialised on EU law, Academia,
Italy
7. Mariana da Cunha Legal Expert and President of NGO, Specialised on EU law, International Law,
Criminal law, Women's rights and Violence against Women , NGO- Civil society, Netherlands
8. ELENI KALLEA LIAISON OFFICER, Specialised on EU law, EUROPEAN COMMISSION,
Belgium
9. Joana Gama Gomes Guest Lecturer University of Lisbon School of Law, Specialised on EU law,International Law, Academia, Legal Counselling Services, Portugal
10. Marnie Delaney Chair, VAW Task Force, Specialised on Advocacy, NGO- Civil society, France
11. Michela Procoli Program Manager, Specialised on Political Science, NGO- Civil society, Belgium
12. Julia Runte Project Officer/human rights, Specialised on International Law, NGO- Civil society,
Global
13. Cristina Puigdengolas Practising attorney , Specialised on Criminal law, THB, Astlym, minors,
human rights, Court, Legal Counselling Services, NGO- Civil society, Spain
14. Esmeralda Fanti Unemployed, Specialised on Global justice, NGO- Civil society, Italy
15. Micaela Frulli Full Professor , Specialised on International Law, Academia, NGO- Civil society,Italy
16. Deborah Russo Associate professor of international law, Specialised on International Law,
Academia, Italy
17. Antonietta Elia Distinguished Professor of Law and Senior Legal Adviser, Specialised on EU law,
Constitutional Law, International Law, Criminal law, Academia, Legal Counselling Services, NGOCivil society, Global
18. Veronica Zaboia Policy and Campaigns officer , Specialised on EU law, NGO- Civil society,
Belgium
19. IVONE SOARES MEMBER OF PARLIAMENT AND UNIVERSITY PROFESSOR, Specialised
on POLITICAL SCIENCE, PARLIAMENT , MOZAMBIQUE

6

20. Liam O’Driscoll PhD Researcher , Specialised on EU law, Criminal law, Academia, Ireland
21. Nikolina Zec Legal adviser, Specialised on International Law, Criminal law, NGO- Civil society,
Croatia
22. Claudia Ruiz Campos Student, Specialised on EU law, International Law, Academia, Belgium
23. Maitane González Pérez Lawyer, Specialised on EU law, Private Law Firm, NGO- Civil society,Spain
24. Mireille Boffa Lawyer, Specialised on Asylum and human rights, NGO- Civil society, Malta
25. Sarah Cadiot Lawyer, Specialised on Privacy law, In-house counsel, France
26. Berthe De Vos-Neven UN Representative Geneva , Specialised on EU law, International Law,
Labour Law, Legal Counselling Services, NGO- Civil society, Belgium
27. Alexis Galand Legal Officer, Specialised on EU law, International Law, NGO- Civil society, Malta
28. Maria Resende Research Scholar, Specialised on EU law, International Law, Antidiscrimination
Law, Academia, Portugal
29. Segolene Chesneauorganisation, France

Human rights lawyer, Specialised on International Law, International

30. Alyssa Nadia Ahrabare Advocacy and Legal Lead , Specialised on EU law, International Law,
NGO- Civil society, Belgium
31. Esohe Aghatise Dr/Jurist, Specialised on International Law, Economic and Trade Law, Academia,
Legal Counselling Services, NGO- Civil society, Italy
32. Carla Canale Lawyer, Specialised on Constitutional Law, Private Law Firm, Italy
33. Mathias Möschel Associate Professor , Specialised on EU law, Constitutional Law, InternationalLaw, Academia, Austria
34. Noura RAAD Lawyer , Specialised on International Law, Criminal law, Asylum , Academia,
Private Law Firm, Court, France
35. Ange-Hélène YEBGA HOT lawyer , Specialised on EU law, Real estate Law, Private Law Firm,
France36. Chiara Parolin Lawyer , Specialised on International Law, Private Law Firm, Italy
37. AGNES MARIE Thery Teacher, Specialised on EU law, NGO- Civil society, Italy
38. Diana Vaquero Administrative assistant DG ECHO, European Commission, Specialised on Gender
Equality , Survivor of sexual violence., Belgium
39. Lina Atelj Judicial trainee, Specialised on civil law, Court, Slovenia

740. Snieguolė Benikienė Lawyer, Specialised on Family law, NGO- Civil society, Lithuania
41. Danuta Wawrowska advocate, Specialised on Criminal law, Private Law Firm, Poland
42. Renata Durda specialist in counteracting domestic violence, Specialised on Criminal law, , Poland
43. Anita Kucharska-Dziedzic MP and legal practitioner, Specialised on Criminal law, Parliament,
Poland
44. Witold Klaus Professor, Specialised on Criminal law, Academia, NGO- Civil society, Poland
45. Wojciech Burek Professor, Specialised on EU law, International Law, Academia, Poland/Germany
46. Anita Kucharska-Dziedzic Member of Parliament, Specialised on EU law, NGO- Civil society,
Poland47. Monika Ksieniewicz-Mil PR Manager, Specialised on PR, NGO- Civil society, Poland
48. Laura Pastor Legal Advisor, Specialised on EU law, International Law, Legal Counselling Services,
Belgium
49. MARIA JOSE CARRETERO GONZALEZ Lawyer, Specialised on Criminal law, FAMILY LAW,
Private Law Firm, NGO- Civil society, Spain
50. Dagmara Woźniakowska Professor, Specialised on Criminal law, Criminology, Academia, Poland
51. Katarzyna Wilkołaska Lawyer , Specialised on EU law, Constitutional Law, International Law,
Expert, Poland
52. Dovilė Maslaksienė Lawyer, Specialised on family law, NGO- Civil society, Lithuania
53. Lidia Mazowiecka President of the Management Board, Victim Support Foundation, Specialisedon Criminal law, NGO- Civil society, Poland
54. Emilija Kazanceve Psychologist, lawyer, consultant, Specialised on EU law, International Law,
Private Law Firm, Legal Counselling Services, NGO- Civil society, Lithuania
55. Gabrielė Šinkonė Attorney at law, Specialised on Criminal law, Commercial litigation, Labor law,
Family law, Family business strategist, Inheritance law, Private Law Firm, Lithuania
56. Lina Miežinienė lawyer, Specialised on Criminal law, Private Law Firm, Lithuania
57. Lara Dimitrijevic Lawyer, Specialised on Criminal law, Civil, Legal Counselling Services, NGOCivil society, Malta
58. Agata Czarnacka Writer, Specialised on Constitutional Law, International Law, Combatting
gender-based violence, NGO- Civil society, Media, Poland
59. Kaltrina Shala Manager Political Dialogue and Legislative Processes, Weizenbaum Institute,
Specialised on EU law, Constitutional Law, International Law, ICT Law, Research Institute, Germany

860. Dr Claire Fourçans EU Law Public affairs, Specialised on EU law, Criminal law, NGO- Civil
society, Belgium
61. Mtr. Isabelle Steyer Lawyer, Specialised on EU law, Criminal law, Private Law Firm, France
62. Prof. Dr. Sc. Snježana Vasiljević Professor M. Phil (Cantab) University of Zagreb - Faculty ofLaw, Specialised on EU law, Constitutional Law, Academia, Croatia
63. Liam Boylan Lawyer, Specialised on Antitrust, Private Law Firm, UK / Belgium
64. Aslihan Tekin Ozgen Lawyer, Independent Consultant , Specialised on EU law, ConstitutionalLaw, International Law, Digital rights, NGO- Civil society, Belgium and Türkiye
65. Anna Grędzińska Gender equality specialist, Specialised on EU law, gender equality, diversity andinclusion, Academia, Poland
66. Carmen MUÑOZ Professor, Specialised on International Law, Academia, Spain
67. Daniela Stojkovic Self employed , Specialised on Dutch administrative law, Self employed, but
working for Dutch Childcare benefits scandal agencie(s), Netherlands
68. Maria Paz de la Usada Pampliega Lawyer, Specialised on Criminal law, , Spain
69. Dijana Malbasa Master of Laws (LL.M.), Specialised on Gender equality and Family law, NGOCivil society, Serbia
70. ANDREA SPADA JIMENEZ Professor Malaga University, Specialised on EU law, InternationalLaw, Criminal law, PROCEDURAL LAW, CRIMINAL AND CIVIL PROCEEDINGS, Academia,
Spain
71. Rosa Maria Fernández Sansa Professor History, Specialised on Law, NGO- Civil society, Spain
72. Patricia Viviana Ponce Pascuale Directora y gestora de programas de mujeres , Specialised on
Women DDHH , NGO- Civil society,73. FÓRUM DE POLÍTICA FEMINISTA NGO, Specialised on EU law, Spain
74. Asociacion Feminista Mercedes Machado NGO, Specialised on National law, Education, NGOCivil society, Spain
75. Olga María Barrera Trujillo Presidenta Federación de Asociaciones de Mujeres Arena y Laurisilva,
Specialised on EU law, NGO- Civil society, Spain
76. Gloria Alarcon García Professor , Specialised on EU law, Academia, Spain
77. Coordinadora de Mujeres para la participacion y la igualdad COMPI Coordinadora de asociaciones
mujeres, Specialised on Criminal law, ADvocacy , NGO- Civil society, Spain
78. Lucy Polo Castillo Presidenta , Specialised on EU law, NGO- Civil society, Spain979. María Acale Sánchez Catedrática de Derecho penal (Universidad de Cádiz), Specialised on
Criminal law, Academia, Spain
80. JUAN MARIA TERRADILLOS Professor emeritus, Specialised on Criminal law, Academia,
Spain
81. Laura Chiticariu Lawyer, Specialised on Criminal law, Legal Counselling Services, NGO- Civil
society, Romania
82. Efthymia Ioannidou Lawyer , Specialised on EU law, Private Law Firm, NGO- Civil society,
Greece83. Patricia Faraldo Cabana Professor of Criminal Law, Specialised on Criminal law, Academia, Spain
84. Grzegorz Wrona Council, Specialised on Criminal law, Court, Poland
85. Vicenta Monge Retired, Specialised on Equality Legislation, NGO- Civil society, Spain
86. Nuria Arenas Professor International Law, Specialised on EU law, International Law, Academia,
Spain
87. Maria Luisa Alvarez Licenciada en Derecho, Specialised on EU law, , Spain
88. Jana Javornik Academic, Specialised on gender equality and EDI in the labour markets , Academia,
NGO- Civil society, United Kingdom / Slovenia
89. Andreja Gomboc Professor, Academia, Slovenia
90. Laura Elena Chiticariu lawyer, Specialised on Criminal law, CIVIL LAW, Private Law Firm, NGOCivil society, Romania
91. Michelle Nipps-Gros Physiotherapist, Specialised on medical, medical rehabilitaion, France
92. Katarina Bervar Sternad Lawyer, NGO Director , Specialised on Human Rights law, NGO- Civil
society, Slovenia
93. María Nieves Saldaña Díaz Professor on Constitutional Law, Specialised on Constitutional Law,
Academia, Spain
94. María del Rosario Gómez López Profesora de Derecho Penal , Specialised on Criminal law,
University, Spain
95. Ph.D. Ciril Ribičič Former Judge of the Constitutional Court in Slovenia, Specialised on EU law,
Constitutional Law, Court, Slovenia
96. Melanie Kocsan-Göschl Legal expert, Specialised on Labour Law, chamber of labour, Austria
97. Alice Wagner Senior Policy Officer, Specialised on EU law, Labour Organisation, Belgium
98. Eliana Zatschler Secretary General, Specialised on EU law, NGO- Civil society, Belgium

1099. Piotr Pawłowski Legal advisor, Specialised on Criminal law, Medical Law, Educational Law,
Private Law Firm, NGO- Civil society, Poland
100.
Charlotte Olhausen European Union of the Deaf Policy Officer, Specialised on EU law,NGO- Civil society, Belgium
101.

Nicole Reiter Mag., Specialised on EU law, Chamber of Labor, Austria

102.

Isabella Heugl Mag, Specialised on Employment Law, NGO- Civil society, Austria

103.
Sandra Konstatzky Head of Nationa Equality Body, Specialised on EU law, National
Equality Body, Austria
104.
Evelyn Regner Vice President of the European Parliament, Specialised on EU-Arbeitsrecht& Gesellschaftsrecht, MEP (S&D Austria), EU
105.
Ludwig Dvorak Bereichsleiter , Specialised on EU law, Labour Law, Trade Union,
Chamber of Labour, Austria
106.

Ruth Ettl Legal Counsellor, Specialised on Labour Law, Trade Union, Austria

107.

Titti Carrano Lawyer, Specialised on International Law, Private Law Firm, Italy

11