JOINT STAFF WORKING DOCUMENT The EU Special Incentive Arrangement for Sustainable Development and Good Governance ('GSP+') assessment of Armenia covering the period 2018 - 2019 Accompanying the document Joint Report to the European Parliament and the Council Report on the Generalised Scheme of Preferences covering the period 2018-2019
Date: 2020-02-10
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: Armenia, EU market, common commercial policy, development aid, generalised preferences, human rights, international convention, sustainable development, tariff preference

EN 

  EN 

   EUROPEAN COMMISSION HIGH REPRESENTATIVE OF THE UNION FOR FOREIGN AFFAIRS AND SECURITY POLICY Brussels, 10.2.2020  SWD(2020) 17 final  JOINT STAFF WORKING DOCUMENT  The EU Special Incentive Arrangement for Sustainable Development and Good Governance ('GSP+') assessment of Armenia covering the period 2018 - 2019 Accompanying the document Joint Report to the European Parliament and the Council Report on the Generalised Scheme of Preferences covering the period 2018-2019       {JOIN(2020) 3 final} - {SWD(2020) 16 final} - {SWD(2020) 18 final} - {SWD(2020) 19 final} - {SWD(2020) 20 final} - {SWD(2020) 21 final} - {SWD(2020) 22 final} - {SWD(2020) 23 final} - {SWD(2020) 24 final} - {SWD(2020) 25 final}  
 
 
Armenia  

1. Summary Assessment 

Following  the  Velvet  Revolution  and  democratic  changes  of  2018,  the  Government  of 
Armenia has made commitments regarding the respect of human rights and good governance 
and started taking legislative and other steps to implement those commitments. The results are 
yet to be seen. While fully transforming the system will take time, Armenia is now a country 
in  transition,  demonstrating  strong  political  will  for  democratisation.  The  new  authorities' 
agenda prioritises areas  where the EU has been  traditionally advocating  change. Armenia is 
making  progress  over  time  on  the  27  GSP+  conventions,  though  concerns  remain  on  the 
implementation of the reforms.  

Priorities 
During  the  reporting  period  2018-2019,  monitoring  focused  on  several  priority  areas:  the 
adoption  of  new  Judicial  and  Criminal  codes,  as  well  as  a  standalone  law  against  domestic 
violence; anti-corruption measures and prosecutions; and the draft Law on Ensuring Equality. 
Furthermore, there was focus on progress on aligning domestic legislation on illegal trade of 
endangered  species  and  biosafety  with  international  standards.  A  GSP+  monitoring  mission 
took  place  in  September  2018,  in  connection  with  the  first  EU-Armenia  Partnership 
Committee in Trade Configuration.  

Human Rights 
Improvements in freedom of assembly took place following the Velvet Revolution of 2018. 
Progress  was  noted  in  legislation  on  Domestic  Violence  and  its  implementation,  including 
improving support services for survivors and awareness-raising activities. Also, the legislative 
framework  on  gender  equality  was  improved.  The  ratification  of  the  Council  of  Europe 
Convention  on  preventing  and  combatting  violence  against  women  and  domestic  violence 
(known  as  the  Istanbul  Convention)  is  high  on  the  agenda  of  the  Armenian  government, 
although  finalisation  is  not  expected  in  2019.  Furthermore,  the  Armenian  Human  Rights 
Defender notes a decline in the use of pre-trial detention. Increased oversight of practices 
of  ill-treatment  and  torture  in  the  police  is  expected  with  the  introduction  of  video 
surveillance systems in interrogation rooms in 2019 and 2020.  

However, there are some delays in adopting a new Criminal Code and a stand-alone law on 
anti-discrimination.  A  draft  Law  on  Ensuring  Equality  was  published  in  March  2018;  the 
new government has launched a new discussion on the topic and plans to finalise a draft at the 
beginning  of  2020.  A  series  of  cases  of  hate  speech  and  harassment  against  LGBTQI 
people  continue  to  challenge  the  generally  positive  environment  surrounding  democratic 
change. On 23 May 2019, the EU issued a local statement calling for better protection of the 
human rights of sexual minorities in the country1.  

The  government  has  declared  independence  and  accountability  of  the  judiciary  as  a  top 
political  priority, while some concerns remain. Efforts  so far include the  adoption of a  new 
Judicial  Code  in  April  2018;  a  2019-2023  Strategy  and  Action  Plan  for  judicial  and  legal 
reforms, which is currently awaiting the Government’s approval; the introduction of several e-

1 https://eeas.europa.eu/delegations/armenia/60790/statement-behalf-delegation-european-union-and-eu-
member-states-embassies-resident-armenia_en 

1 

 
                                                 
governance  tools;  and  the  planned  adoption  of  the  Criminal  Code,  and  Criminal  Procedure 
Code (for 2020). 

Labour Rights 
Limited progress was observed during the monitoring period but the new government showed 
commitment and resumed work to address key issues, such as the re-establishment of a fully-
fledged labour  inspection  system and the  revision  of  the  Labour  Code.  The signing of a 
new  Decent  Work  Country  Programme  between  Armenia  and  the  ILO  in  May  2019  is  a 
promising step to advance on issues such as the labour inspection system.  

In  2019,  ILO  lifted  its  concerns  about  the  use  of  correctional  labour  as  punishment  for 
political or ideological views, which is a positive development. 

The preparation of a new Labour Code was dropped in favour of amending the existing one. 
Amendments  were  prepared  in  2018  and  work  continues  under  the  new  government,  which 
plans  to  finalise  amendments  by  2021.  The  amendment  adopted  in  June  2019  to  prohibit 
discrimination  is  a  significant  achievement,  especially  as  adoption  of  a  stand-alone 
comprehensive  anti-discrimination  law  is  still  pending;  however,  several  other  deadlines 
were missed.   

On  labour  inspections,  timid  steps  were  made  so  far  and  the  existing  labour  inspectorate 
remains without sufficient competences and capacity outside occupational health and safety to 
effectively  enforce  the  eight  fundamental  conventions.  The  new  government  has,  however, 
engaged in a roadmap with the ILO to be completed by October 2020. Parliament has pased 
amendments  to  the  Labour  Code  to  extend  the  mandate  of  the  Labour  Inspectorate.  Re-
establishing  a  fully-fledged  labour  inspection  system  in  line  with  the  corresponding  ILO 
conventions ratified by Armenia remains a priority. 

More  effort  is  needed  on  child  labour.  A  majority  of  working  children  are  in  unpaid  or 
informal  employment  and  cannot  benefit  from  the  protection  of  the  legislation  on  child 
labour.  The  Health  and  Labour  Inspectorate  remains  without  sufficient  capacity  to  enforce 
child  labour  legislation  and  there  is  no  other  competent  agency.  The  definition  of  forced 
labour in national legislation still needs to be brought in line with the ILO conventions and 
more  efforts  are  needed  to  curb  the  risks  of  forced  labour  and  labour  exploitation  for 
economic migrants to and from Armenia. 

Environment 
The  ratification  of  the  Kigali  Amendment  to  the  Montreal  Protocol  on  Substances  that 
Deplete  the  Ozone  Layer  signals  Armenia’s  commitment  to  international  environmental 
standards. Furthermore, the authorities reported progress in aligning national legislation with 
the  Convention  on  International  Trade  in  Endangered  species  of  Wild  Fauna  and  Flora 
(CITES)  requirements,  while  full  alignment  is  still  pending.  Concerns  remain  around  low 
penalties  for  violations  of  CITES  and  the  Cartagena  Protocol  on  Biosafety.  These  are  not 
expected  to  have  a  serious  deterrent  effect.  Lack  of  capacity  and  financing  needs  to  be 
addressed.  

Good Governance  
Armenia  maintains  good  international  cooperation  in  the  area  of  drug  control.  Anti-
corruption  has  been  flagged  as  a  main  priority  for  the  new  Government,  with  efforts 
currently focused on addressing corruption in the judiciary.  

2 

 
Status of ratification and reporting 
Armenia  maintained  ratification  of  all  27  Conventions  required  by  GSP+  and  has  mostly 
reported  according  to  requirements  (see  annex).  Armenia  did  not  comply  with  reporting 
obligations on two human rights conventions (the United Nations Convention on the Rights of 
the Child – CRC and the International Covenant on Economic, Social, and Cultiral Rights  -
ICCPR) and one environmental convention (CITES).  

2. Recent developments  

Profound  political  changes  took  place  in  Armenia.  In  April-May  2018,  there  were  mass 
peaceful  protests  (the  so-called  ‘Velvet  revolution’),  which  ousted  former  authorities  from 
power  and  brought  democratic  changes  to  the  country.  Early  parliamentary  elections  were 
held on 9 December 2018, in full respect of the fundamental freedoms and with broad public 
trust2. This was in contrast with previous parliamentary polls, marred by malpractice and lack 
of a genuinely democratic environment3. 

EU-Armenia  relations  also  entered  a  new  stage.  The  Comprehensive  and  Enhanced 
Partnership Agreement (CEPA) was signed in the margins of the Eastern Partnership Summit 
in Brussels on 24 November 2017. The Armenian parliament ratified CEPA unanimously on 
11 April 2018 and the European Parliament gave its consent on 4 July 2018. The provisional 
application of CEPA began on 1 June 2018 and a detailed CEPA  Implementation Roadmap 
was adopted by decision of the Armenian Prime Minister on 1 June 2019. The Roadmap was 
welcomed by the EU-Armenia Partnership Council held in Brussels on 13 June 2019.  

The  new  Government  is  committed  to  human  rights  and  pursues  democratic  reforms, 
including a comprehensive justice reform. Armenia has embarked on the process of structural 
reforms  ensuring  the  rule  of  law  and  modernisation  of  the  country,  with  a  special  focus  on 
building an open economy. The Government announced a series of reforms in early February 

EU- Armenia Development Cooperation 

The EU is the largest donor to Armenia. The Single Support Framework for Armenia for 
2017-2020  is  based  on  the  EU-Armenia  Partnership  Priorities  and  contributes  to  the 
implementation  of  the  20  Deliverables  for  2020  agreed  in  the  context  of  the  Eastern 
Partnership.  

EU assistance to Armenia was indicatively programmed between €144 million and €176 
million for 2017-2020. In addition, Armenia benefited from funds in the Annual Action 
Programme  2018  (€10  million).  In  recognition  of  Armenia's  progress  since  the 
political  transformation  with  regard  to  citizen's  rights,  justice,  equality,  dignity,  and 
individual  freedoms  and  in  recognition  of  Armenia's  determination  to  pursue  a  reform 
agenda  and  to  implement  the  Comprehensive  and  Enhanced  Partnership  Agreement 
(CEPA) effectively, Umbrella funds of €25 million were added to our initial support for 
2019, bringing the total 2019 envelope to €65 million. 

The EU has a substantial portfolio focused on supporting the reform agenda, the focal 
regions  (Shirak,  Lori  and  Tavush),  private  sector  development,  and  infrastructure 
investments (blending). In particular, more than €800 million in the form of blended loans 
and grants has been invested in energy, agriculture, and transport sectors. EU assistance is 
focused  on  the  swift  implementation  of  CEPA,  including  through  a  CEPA  Reform 
Agenda Facility which can provide expertise of High Level Advisors in selected sectors 
(€23 million) and CEPA banking facility providing support to private sector in adjusting 
to the requirements of the Agreement (€10 million). 

2 Statement of Preliminary Findings and Conclusions of the International Election Observation Mission (9 
December 2018 elections): https://www.osce.org/odihr/elections/armenia/405890 
3 OSCE/ODIHR Election Observation Mission Final Report (2 April 2017 elections): 
https://www.osce.org/odihr/328226 

3 

 
                                                 
2019 with a new five-year Programme. Good governance and the fight against corruption are 
among  the  Government's  top  priorities.  While  fully  transforming  the  system  will  take  time, 
Armenia is now a transition country demonstrating strong political will for democratisation, 
with  the  new  authorities'  agenda  prioritising  areas  where  the  EU  has  been  traditionally 
advocating change.4  

The  Azerbaijani-Armenian  and  Turkish-Armenian  borders  are  closed  in  view  of  the 
unresolved Nagorno-Karabakh conflict. Only two borders, with Georgia in the north and Iran 
in the south, remain open. This seriously affects Armenia's economic performance, hampering 
both imports and exports.  

3. EU-Armenia trade and GSP 

In 2018, Armenia's economy grew by 5.2%, following a growth of 7.5% in 2017. According 
to the National Statistical Committee of Armenia, the GDP growth for the first half of 2019 
stood at 6.8%, whereby almost all sectors showed growth except agriculture, which recorded 
a decline. In 2018, the World Bank classified Armenia as an upper-middle income economy 
for the second year in a row.  

Trade  relations  between  the  EU  and  Armenia  are  regulated  by  the  new  Comprehensive  and 
Enhanced Partnership Agreement. The EU accounts for around 25% of Armenia's total trade 
in  2018.  The  EU  is  thus  Armenia's  second  trading  partner  after  Russia  (26%)  and  before 
China (11%). In 2018, total EU imports of goods from Armenia amounted to € 373 million. 
This is a 4.7% decrease compared to 2017, but still reflects a clear upward trend compared to 
previous  years  (€  205  million  in  2015  and  €  351  million  in  2016).  The  2018  EU  imports 
mainly  consisted  of  non-ferrous  metals,  ores  and  other  minerals,  and  clothing.  The  EU 
exported goods worth € 863 million to Armenia in 2018 (a 20.3% growth compared to 2017) 
– mainly machinery and transport equipment, and chemicals. 

Figures 1-3 below describe Armenia's utilisation of GSP+ in the context of the EU's overall 
imports from Armenia5. 

Armenia maintained a GSP+ utlisation rate of over 90%, with a slight drop in 2018. Usage of 
GSP+  continues  to  be  highly  concentrated  on  base  metals  (aluminium,  iron,  and  steel). 
Reported figures  for GSP+ imports to  the EU for 2018 decreased significantly  compared to 
prevous  years.  This  is  largely  the  result  of  a  significant  share  of  EU  imports  from  Armenia 
having been registered as confidential by EU Member States 6.   

4European Commission. Partnership Implementation Report on Armenia, 20 May 2019, 
https://eeas.europa.eu/sites/eeas/files/partnership_implementation_report_armenia.pdf 
5 GSP-statistics only cover goods imported in the EU market, i.e. goods released for free circulation in the EU. 
The GSP statistics do not cover other EU-imports, like goods imported for the customs inward processing 
procedure or re-imports after the customs outward processing procedure 
6 Trade flows registered as “confidential” do not show up in the GSP+ usage figures and regime 1 normal trade; 
but do show up in total trade figures (regime 4). 
https://ec.europa.eu/eurostat/cache/metadata/en/ext_go_agg_esms.htm#conf1537195068659 

4 

 
 
                                                 
 
Figure 1: Armenia imports to the EU 2016-2018 rate 

Figure 2: Armenia imports to the EU 2016-2018  

5 

Armenia - imports to the EU 2016-2018 (M€)201620172018trend 2016-2018Total imports310.0351.1207.9-32.9%GSP+ eligible116.4135.574.9-35.7%GSP+ preferential107.8130.368.2-36.8%Utilisation rate92.6%96.2%91.0%-1.6% 
 
 
 
 
 
 
Figure 3: Product Diversification of GSP+ Preferential Imports, 2018 

Armenia GSP imports to EU 

S-15b base metals

S-11b apparel and clothing

S-04b food preparations

S-04c tobacco

S-14 precious stones, pearls

S-18 optical instruments

0%

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

4. Compliance with GSP+ Obligations 

4.1  UN Human Rights Conventions  

Armenia's  human  rights  situation  has  improved  since  the  political  changes  of  2018,  with 
advances on   freedom  of  assembly. However, several challenges remain with regard to the 
uncontrolled  online  hate  speech  and  in  a  number  of  other  areas,  including  the  penitentiary, 
and  ensuring  freedom  of  expression  for  minority  groups  such  as  religious  and  sexual 
minorities. The new authorities' plans for a comprehensive police reform are encouraging in 
this  regard.  A  series  of  cases  of  death  threats  and  harassment  against  LGBTQI  people 
continue to challenge the generally positive environment surrounding democratic change. On 
23 May 2019, the EU issued a local statement calling for better protection of the human rights 
of sexual minorities in the country.7 

in 

society 

In  2018-2019,  Armenia  continued  to  address 
shortcomings  identified  under  the  GSP+  related 
conventions.  The  Armenian  authorities  also 
sustained  efforts  to  improve  the  involvement  of 
civil 
implementation  and 
monitoring  of  the  2017-2019  National  Human 
Rights  Action  Plan  (NHRAP).  However,  the 
NHRAP 
and 
evaluation  tools  to  measure  its  progress.    There 
are  some  issues  with  the  quality  of  the  Action 
Plan  and  its  implementation.  These  are  mainly 

effective  monitoring 

lacks 

the 

Promoting  Human  and  Labour 
Rights  in  Armenia  through  GSP+ 

implementing 

Starting  from  February  2018, 
the 
Eurasia  Partnership  Foundation  (EPF) 
this  EU-funded 
is 
project in Armenia with the support of 
Democracy  Reporting 
International 
(DRI).  The  project  aims  to  strengthen 
the  capacities  of  Armenian  regional 
CSOs 
in  producing  high-quality, 
evidence-based alternative reports to 
the  UN  Committee  on  Economic, 
Social  and  Cultural  Rights  and  UN 
Committee on the Rights of the Child. 

6 

7 https://eeas.europa.eu/delegations/armenia/60790/statement-behalf-delegation-european-union-and-eu-
member-states-embassies-resident-armenia_en 

 
 
                                                 
 
due to the lack of inter-sectorial cooperation compromises.  

In February 2019, the government launched the process of developing the new NHRAP 2020-
2022.  Civil  Society  Organisations  (CSOs)  consider  this  process  a  priority  for  the  proper 
implementation  of human rights  and should be included in  the  coordination  council for this 
Action Plan.  It  is  important  that the new Human Rights  Strategy and Action  Plan sets  clear 
priorities,  contains  measurable  indicators,  and  ensures  a  proper  monitoring  mechanism.  The 
government plans to circulare the draft NHRAP by the end of 2019. 

In  September  2019  Armenia  signed  the  Second  Optional  Protocol  to  the  International 
Covenant on Civil and Political Rights, aiming at the abolition of the death penalty and also 
the  Optional  Protocol  to  the  Convention  on  the  Rights  of  the  Child  on  a  communications 
procedure,  a  positive  development.  Armenia  was  elected  as  a  member  of  the  UN  Human 
Rights Council on 17 October 20198. 

International  Convention  on  the  Elimination  of  All  Forms  of  Racial 
Discrimination (CERD) 

The four largest ethnic minorities – Yezidi, Assyrians, Russians, and Kurds -  are represented 
in  the  Armenian  National  Assembly,  in  accordance  with  Armenia's  electoral  legislation. 
However,  challenges  remain  in  the  way  of  further  increasing  tolerance  of  diversity  in 
Armenian society and tackling discrimination of ethnic minorities.  

A draft Law On Ensuring Equality was developed by the Ministry of Justice and was put for 
public discussions into e-draft platform in 2018. This draft Law envisaged guarantee of equal 
opportunities  for  each  person  to  exercise  their  rights  and  freedoms.  The  draft  Law  also 
ensured  the  creation  of  a  specialised  equality  body  under  the  Human  Rights  Defender’s 
Office, creating mechanisms for assistance to victims of discrimination and for examination in 
alleged cases of discrimination. The Ministry of Justice published a new version of the draft 
Law in July 2019. The adoption of the law is a benchmark of the EU-Armenia Human Rights 
Budget Support programme. The government has launched new discussions on the draft Law 
and plans to finalise a draft legal act in the beginning of 2020.  

Civil  society  organisations  have  expressed  concern  that  the  equality  body  as  set  up  by  the 
draft Law, and implementation in general, would be ineffective; and that the list of protected 
grounds as currently stated is incomplete, as it does not include the state of health, maternity, 
pregnancy,  sexual  orientation,  gender  identity,  place  of  residence  and  economic  status. 9 
Discrimination on the basis of sexual orientation, which is not covered by the draft Law on 
Ensuring Equality, remains a highly sensitive issue. 

 International Covenant on Civil and Political Rights (ICCPR) 

Following  the  Velvet  revolution,  a  number  of  persons  allegedly  detained  on  political 
grounds were released from detention. Visible efforts were made to discontinue the practice 
of excessive use of pre-trial detentions. Furthermore, a large-scale amnesty was announced in 
November 2018.  

The  new  government  declared  achieving  independence  of  the  judiciary  a  top  political 
priority. According to civil society partners, demonstrated political will in this regard played a 

8 https://www.rferl.org/a/armenia-elected-un-human-rights-council/30222721.html 
9 Eurasia Partnership Foundation - DRI report. 

7 

 
                                                 
critical  role  in  significantly  limiting  practices  of  direct  intervention  of  the  executive  into 
judicial proceedings. The handling of several high-profile anti-corruption cases against former 
government  officials  will  be  an  important  signal  of  the  new  government’s  commitment  to 
judicial  independence.  Furthermore,  to  address  systemic  issues  in  the  justice  sector,  the 
Government  launched  a  public  discourse  in  May  2019  on  the  introduction  of  ‘transitional 
justice’ elements in Armenia.  

EU- Armenia Policy Dialogue on Justice Reforms 

The EU-Armenia justice policy dialogue was lanched in September 2018 with the aim 
to support a comprehensive justice reform. 

The EU has provided support aimed at strengthening government’s capacity to develop 
a  comprehensive  strategy  and  implement  the  reform  in  the  framework  of  the 
Consolidation of the Justice System in Armenia programme (€4 million). Short-term 
assistance has been mobilised through the TAIEX instrument to support the costing and  
and share lessons learnt from reform efforts in other partner countries. 

The EU  is ready to mobilise further resources to support the implementation of  reform 
through  a  sector  reform  performance  contract  (budget  support)  and  assist  with  further 
assessment  through  the  EU-funded  Justice  Survey  project  and  a  comprehensive 
functional review of the justice system. 

The  new  Judicial  Code  was  adopted  by  the  National  Assembly  on  7  February  2018  and 
entered  into  force  on  9  April  2018.  The  adoption  of  new  Criminal  Code  and  Criminal 
Procedure  Code  is  planned  during  2020.  Overall,  these  new  codes  are  in  line  with 
international  standards  and  in  respect  of  the  relevant  international  conventions.  Work  is 
ongoing on the establishment of procedures for the verification of the professional integrity of 
the  judges,  as  well  as  on  other  aspects  aimed  at  ensuring  the  accountability,  efficiency  and 
independence of the judiciary from political and party influence and at increasing public trust 
in the courts.   

The ambitious new Justice Reform Strategy 2019-2023 and its Action Plan were finalised in 
record  time  by  the  new  Government  and  adopted  in  October  2019.  Furthermore,  between 
2010  and  2019,  e-governance  tools  have  been  introduced  in  the  justice  sector  of  Armenia, 
including the e-Civil Status Registry, the e-Police component, the e-Citizen portal, the on-line 
Interactive  Portal  for  draft  laws,  e-Notary,  e-Penitentiary,  and  e-Apostille,  leading  to  a 
reduction of corruption risk and an increase in efficiency in the justice system.  

International Covenant on Economic, Social and Cultural Rights (CESCR) 

Since  the  breakout  of  the  Syrian  crisis  in  2011,  Armenia  received  some  22,000  Syrian 
refugees  of  Armenian  origin.  EU  support  to  Syrian  refugees  in  Armenia  continued  in  2018 
with  a  new  project  focusing  on  improving  the  social  and  economic  resilience  of  Syrian 
Armenians and the host population, and on strengthening relevant institutional capacities for 
economic growth in Armenia. 

Discrimination  of  vulnerable  groups,  such  as persons  with  disabilities,  LGBTQI  people, 
and  national  minorities,  in  particular  children  from  ethnic  and  religious  minorities,  requires 
further  policy  changes,  including  a  stand-alone  anti-discrimination  law.  A  new  and 
comprehensive law on National Minorities is pending adoption.  

8 

 
 
 
For persons  with  disabilities, employment and education as well as polling stations remain 
hardly accessible. The government discussed addressing some of these issues in the draft law 
on the Rights of Persons with Disabilities. The National Disability Commission was dissolved 
by  the  new  government.  The  process  of  forming  the  new  Commission  is  not  transparent, 
according to some CSO partners. Reform of public transportation that would address concerns 
of  people  with  disabilities  is  pending.  Labour  rights  of  persons  with  disabilities  are  not 
addressed. The ongoing  exercise of developing amendments  to  improve the  Labour Code is 
meant  to  raise  awareness  of  discrimination  in  employment  and  address  the  existing 
shortcomings.  Inclusive  education  policy  is  not  well  implemented,  as  the  resources  and 
capacities  are  not  sufficient  to  ensure  that  children  with  disabilities  can  be  adequately 
integrated  in  public  schools.  A  2017-2021  Strategy  on  Social  Inclusion  of  Persons  with 
Disabilities and 2018 Annual work plan on Social Inclusion of Persons with Disabilities and 
its Action Plan are in place.  

Convention  on  the  Elimination  of  All  Forms  of  Discrimination  Against 
Women (CEDAW) 

A  Law  on  Prevention  of  Domestic  Violence  and  Protection  of  the  Victims  of  Domestic 
Violence was passed by the National Assembly in December 201710. Overall, the Law ensures 
preventive  and  protective  mechanisms,  as  well  as  state  assistance  for  domestic  violence 
survivors. The Law is partially in compliance with the CEDAW General recommendation No. 
19 on gender-based violence and with the Council of Europe Convention on Preventing and 
Combating Violence against Women and Domestic Violence (Istanbul Convention).  

In  February  2018,  the  Armenian  Government  approved  the  Action  Plan  for  the 
implementation of the Law on Domestic Violence, and in July 2018 set up the Council on 
Prevention  of  Violence  in  the  Family, the coordination body for policies on prevention of 
domestic violence. The Government also drafted relevant decrees regulating requirements for 
shelter  staff  members  and  establishing  a  centralised  record  of  domestic  violence  cases.  In 
2019, the Government  aims to  increase the number of shelter spaces and establish  state-run 
shelters; and to  conduct  campaigns to  educate the public about  the new law, on how to  file 
complaints, and about the availability of services. In discussions with the Council, the Police 
stressed  several  persisting  problems  with  regard  to  the  adoption  of  by-laws  necessary  for 
implementation of the Law. One of the main impediments is the lack of referrals of juveniles 
who exercise violence in the family to rehabilitation centres on one hand, and the lack of such 
centres on the other.    

During  the  second  half  of  2018,  990  cases  of  violence  within  the  family  were  registered  in 
Armenia;  in  431  cases  a  warning  was  issued,  and  in  131  cases  imminent  measures  of 
interference were applied.    

the 

In  January  2018,  the  Republic  of  Armenia 
signed 
Istanbul  Convention.  The 
ratification  of  the  Convention  is  high  on  the 
agenda  of  the  new  Government  and  National 
Assembly.  In    May  2019,  the  Ministry  of 
Justice 
ratification 
procedures.  However,  the  process  has  been 
highjacked  by  homophobic  and  pseudo-

initiated 

internal 

the 

In  April  2019,  the  Council  of  Europe 
Office  in  Armenia  launched  a  new  2,5-
year  project  Preventing  and  combating 
violence  against  women  and  domestic 
violence  in  Armenia:  continuing  the 
the 
towards  ratification  of 
path 
Istanbul Convention (€600,000), funded 
by the governments of Liechtenstein and 
Norway.  The  project  aims  to  prepare 
Armenia for the Istanbul Convention; and 
to  ensure  the  Armenian  legal  and  policy 
framework  on  preventing  and  combating 
domestic  violence  will  be  in  line  with 
Council of Europe standards. 

9 

10 For details, please refer to the biennial report for 2016-2017, SWD(2018) 32 final of 19.1.2018 

 
                                                 
homophobic groups questioning the definition of gender given in the Convention. 

The  Ministry  of  Labour  and  Social  Affairs  announced  the  start  of  a  five-year  Gender 
Strategy  (2019-2024).  To  ensure  the  continuity  of  gender  policy  and  take  into  account  the 
existing  issues  and  new  challenges  to  achieving  gender  equality,  the  new  Government  is 
developing  a  draft  Strategy  and  Programme  of  Activities  for  Implementation  of  Policy  on 
Ensuring  Equal  Rights  and  Equal  Opportunities  for  Women  and  Men  in  the  Republic  of 
Armenia  for  2019-2023.  The  Strategy  defines  the  priority  directions  of  the  state  policy  on 
equal  rights  and  equal  opportunities  for  women  and  men  and  aims  to  create  favourable 
conditions  for  women  and  men  in  all  areas  of  public  life.  The  draft  has  been  finalized  and 
made public on 21 May 201911, but has not been approved yet.  

A draft decree on the establishment of a new Council of Issues on Equality between Men 
and Women is currently under consideration by the Government since May 2019. The decree 
proposes  the  revision  of  the  Council’s  functions  and  powers,  strengthening  its  capacity  to 
effectively  monitor  and  implement  policies  on  gender  equality  and  taking  into  account 
CEDAW’s recommendations from Armenia’s Fifth and Sixth Periodic Reports.  

Convention  against  Torture  and  Other  Cruel,  Inhuman  or  Degrading 
Treatment or Punishment (CAT) 

Ill-treatment,  torture,  inhumane  and  degrading  treatment  are  explicitly  prohibited  by  law. 
Development  of  specific  legislative  safeguards  (e.g.  through  amendments  to  the  Criminal 
Procedure  Code,  new  Law  On  Pardon)  is  underway.  Concerns  remain  with  regard  to  the 
continuing practice of ill-treatment and torture, particularly in police custody12, as well 
as  with  regard  to  mechanisms  for  accountability  and  opportunities  for  civic  oversight  of 
closed facilities.  

The  political  developments  in  the  country  resulted  in  a 
change  of  the  police  leadership.  The  new  leadership 
embarked  on  police  reforms,  including  in  the  area  of 
prevention  of  torture.  In  2018,  the  Special  Investigative 
Service  launched  a  number  of  criminal  cases  relating  to 
ill-treatment  committed  by  police  officers.  However, 
official  data  and  information  on  the  outcomes  of  the 
cases is not publicly available. In addition, the Armenian 
police is working on establishing a new patrol police, in 
order to address ill-treatment. 

video 

Under  the  EU’s  Support  to 
Human  Rights  Protection  in 
Armenia  programme, 10 pilot 
police  stations  should  benefit 
from 
surveillance 
systems in interrogation rooms 
in  2019  and  2020.  The  action 
is  aimed  at  decreasing  the 
practice  of  ill  treatment  and 
torture.  The  legal  framework 
was discussed and the terms of 
reference  for  purchase  of  the 
required 
was 
submitted. 

equipment 

continued 

society  organisations 

Civil 
report 
allegations and occurrences of torture and ill-treatment in 
the country. By mid-2018, 71 cases were reported, out of 
which  only  one  was  sent  to  the  court.  Human  Rights  Watch,  in  its  2019  country  report13, 
referred  to  the  events  of  April-May  2018,  specifying  alleged  use  of  stun  grenades  by  the 
police on April 16, leaving 46 people injured, including six policemen.  

to 

11 http://www.mlsa.am/wp-content/uploads/2019/05/naxagic-genderayin-razmavarutyun.docx 
12 https://rm.coe.int/16806bf46f. 
13 https://www.hrw.org/world-report/2019/country-chapters/armenia 

10 

 
 
 
 
 
                                                 
The  Armenian  National  Preventive  Mechanism’s  (under  the  Human  Rights  Defender) 
workload increased significantly during the 2018-2019 reporting period, as it conducted visits 
to penitentiary institutions, social care homes, childcare institutions, and psychiatric centers. 
Three prisons were far below the international standards and need to be upgraded. Regarding 
the lack of quality medical care for prisoners, Armenia plans to establishing special wards in 
public hospitals.  

According to the information presented by the Prosecutor General's Office during the Human 
Rights  Dialogue  (Brussels,  8  April  2019),  there  are    recent  positive  trends  in  terms  of 
decrease of use of pre-trial detention (PTD), as well as decrease of unjustified motions for 
PTD. Instructions to prioritize alternative sentences have already been translated into practice; 
however, legal amendments and strengthening of the Probation Service, including funding for 
GPS monitoring in case of house arrest are needed.  

Convention on the Rights of the Child (CRC) 

The  current  legislative  framework  includes  the  National  Strategy  and  Action  Plan  on  Child 
Rights  Protection  (2017-2021).  Furthermore,  the  Human  Rights  Protection  Strategy  2017-
2021 and its Action Plan include a special chapter on child rights. De-institutionalization of 
the child care system is a priority in the Government Programme for 2017-2022.  

The Child Rights  Unit  under the Human Rights  Defender (HRD) Office is  appointed as the 
CRC monitoring mechanism. UNICEF has been assisting the Child Rights Unit to strengthen 
monitoring.  At  the  same  time,  the  National  Commission  for  the  Protection  of  Children's 
Rights continues to be inactive and fails to perform its mandate. In October 2018, The Human 
Rights Defender’s Office issued a comprehensive ad hoc Report on the State of Fulfilment of 
Armenia's Commitments under the the Convention and its protocols, with recommendations 
in each of the areas covered.14 

Challenges  remain  with  the  ongoing  de-institutionalisation  reforms  meant  to  address  the 
problem  of  overrepresentation  of  children  with  disabilities  in  residential  institutions15, 
where  it  is  believed  their  needs  are  not  addressed  adequately.  Amendments  to  the  Family 
Code were enacted in 2018 to allow for the development and strengthening of alternative care 
system  in  the  country,  including  foster  care  reform.  The  government  has  also  adopted  a 
Concept on the Development of Alternative Services (service centres, foster care and adoption 
mechanisms) 16  and  considers  the  possibility  of  delegating  provision  of  these  services  to 
relevant  civil  society  partners.  However,  before  the  community-based  centres  for  children 
with disabilities envisaged under the EU Human Rights Budget Support Programme would be 
established,  the  existing  arrangements  within  residential  institutions  have  been  abandoned, 
creating a gap in provision of services. Serious issues also persist with the implementation of 
inclusive  education  reform,  as  most  children  with  disabilities  are  effectively  left  out  of 
schools. 

14 
https://www.unicef.org/armenia/media/2116/file/Commitments%20under%20the%20Convention%20of%20the
%20rights%20of%20the%20child-
the%20state%20of%20fulfillment%20by%20Armenia.%20Ad%20Hoc%20public%20report.pdf 
15 http://transmonee.org/country/armenia/  
16 
http://www.ohchr.org/_layouts/15/WopiFrame.aspx?sourcedoc=/Documents/Issues/Disability/ProvisionSupport/ 
NGOs/Save%20the%20Children%20Armenia.doc&action=default&DefaultItemOpen=1. 

11 

 
 
 
                                                 
Armenia  joined  the  Global  Partnership  to  End  Violence  against  Children  as  a  path-
finding country  in  2018.  However,  the  law  on  Domestic  Violence  does  not  envisage 
mechanisms to support child victims of violence.  

Conclusions and priorities  

Improvements in freedom of assembly followed the Velvet Revolution of 2018. Progress was 
noted in legislation on Domestic Violence and its implementation, including support services 
for  survivors  and awareness-raising  activities; as well as work on improving the legislative 
framework  on  gender  equality.  The  ratification  of  the  Istanbul  convention  would  be  a 
significant further step in this direction and should remain a priority for the new government.  
Furthermore,  the  Human  Rights  Defender  notes  a  decline  in  the  use  of  pre-trial  detention. 
Increased over-sight of practices of ill-treatment and torture in the police is expected with the 
delayed introduction of video surveillance systems in interrogation rooms in 2019 and 2020.  

However, we note the delays in adopting a new Criminal Code and stand-alone law on anti-
discrimination.  A  series  of  cases  of  hate  speech  and  harassment  against  LGBTQI  people 
continue  to  spoil  the  generally  positive  environment  surrounding  democratic  change.  The 
government has declared independence of the judiciary as a top political priority, while some 
concerns remain.  

The drafting of a new 2020-2022 Human Rights Action Plan is a priority for the government 
and  civil  society  partners.  The  new  Judicial  Code  entered  into  force  on  9  April  2018. 
However, after the political changes in Armenia during April-May 2018, the Government has 
planned  to  amend  the  Judicial  Code  in  2020  in  order  to  address  the  recommendations  of 
Venice  Commission  and  OSCE/ODIHR.  The  adoption  of  new  Criminal  Code  and  Criminal 
Procedure Code is planned for 2020.  

4.2  ILO Labour Rights Conventions 

The majority of the monitoring process was conducted with the former government. The new 
government confirmed engagement and started acting on key issues, such as the Labour Code 
and the Labour inspectorate. 

The preparation of a new Labour Code was dropped in favour of amending the existing one. 
A package of amendments  submitted to  the Government  in  summer 2018 addressed several 
gaps identified by the ILO in relation to the fundamental conventions. The new Government 
has  confirmed  its  intention  to  amend  the  Labour  Code  in  order  to  respond  to  ILO 
requirements,  but  restarted  the  drafting  process.  Public  discussion  on  the  envisaged 
amendments was launched in May and June 2019. The office of the Human Rights Defender 
issued  a  public  report  with  a  comparative  analysis  of  the  Armenian  Labour  Law  and 
international  standards  in  201917.  A  working  group  involving  key  stakeholders  is  aiming  to 

17 https://www.ombuds.am/images/files/d42f63d5739ccce32e17bc5a53424c7c.pdf 

12 

 
 
 
                                                 
develop draft amendments by 2021. A positive step in this respect was the amendment to the 
Labour Code to define and prohibit discrimination in employment, adopted on 4 June 2019.  

A  new  Health  and  Labour  Inspectorate  was  established  in  April  2018  (Law  on  State 
Administration Bodies), reporting directly to the Government and with limited powers and a 
mandate  limited  to  occupational  health  and  safety  (OSH)  and  guarantees  for  workers  under 
the  age  of  18,  pregnant  or  breastfeeding  women,  and  child  care  workers.  There  is  still  no 
enforcement  body  for  labour  legislation  on  matters  linked  to  general  working  conditions  or 
employment relations (wages, employment contracts, welfare provisions).  

Following  the  initial  steps  in  2018  on  the  labour  inspection  system,  the  government  is 
developing a roadmap towards a fully-fledged inspection system with support from the ILO 
under the EU-funded project, to be finalised by October 2020. Under the Government Plan, 
draft legislation based on the roadmap would be submitted to the Prime Minister in October 
2021.  Parliament  passed  a  package  of  amendments  to  the  Labour  Code  envisaging  an 
extended mandate of the Health and Labour Inspectorate in December 2019. Poor capacities 
of the administration and institutions, coupled with a lack of financial and human resources, 
remain important impediments to effective implementation and progress.  

Freedom of Association and Collective Bargaining (Conventions 87 and 98) 

Gaps  in  the  legislation  remain  to  be  addressed.  A  package  of  amendments  to  the  Labour 
Code  were  presented  to  the  former  Government  in  January  2018,  addressing  some  of  the 
issues  related  to  the  right  to  strike  (e.g.  threshold  to  call  a  strike;  definition  of  minimum 
service  with  the  social  partners).  Work  continued  under  the  new  government  and  a  new 
package of amendments is being prepared. 

Concerns relate to the exclusion of some categories of civil servants, self-employed, liberal 
professions, and informal workers from forming and joining trade unions. Furthermore, issues 
remain around the excessively high minimum membership requirements for the formation 
of  both  trade  unions  and  employers'  organisations;  and  ambiguous  provisions  on  workers' 
representation in the absence of trade unions. 

De  facto,  the  present  legislation  (Labour  Law  and  the  Law  on  Trade  Unions)  continues  to 
discourage  the  formation  of  unions  independent  of  the  majority  and  branch  trade  unions.  A 
draft  bill  to  amend  the  Law  on  Trade  Unions  would  facilitate  the  establishment  of 
independent  trade  unions,  but  maintains  restrictions  for  certain  professions  (police,  judges, 
etc.). It was passed on to the Parliament but is not on the agenda yet. Shortcomings remain in 
the  Law,  which  allows  for  unilateral  termination  of  collective  agreements  in  case  of 
privatisation and/or restructuring of a company and for circumventing the representative trade 
unions for collective bargaining at enterprise level.  

Although  this  is  a  requirement  of  the  Labour  Code,  there  is  still  no  official  registration  of 
collective agreements.  In practice, freedom of association and collective bargaining are also 
constrained  by  the  fact  that  unions  or  workers’  representatives  are  commonly  perceived  as 
fully dependent  on the goodwill of employers (e.g. employer’s informal consent  required to 
establish  a  trade  union  in  the  company),  by  employers’  and  workers’  organisations  both 
lacking expertise and negotiating skills, and by a weak negotiation culture within businesses.  

The new 2018-2020 Decent Work Country Programme (DWCP), signed by Armenia and 
the  ILO  in  May  2019,  includes  activities  relating  to  freedom  of  association  and  collective 
bargaining. 

13 

 
Abolition of Forced Labour (Conventions 29 and 105) 

Existing legislation (Criminal Code, Labour Code) prohibits forced or compulsory labour of 
any form, but still lacks a clear and comprehensive definition of forced labour in line with 
the ILO Conventions. Amendments to the Labour Code are envisaged with a deadline in 2020 
under the 2019-2022 National Action Plan against Trafficking in Persons, which is still to be 
approved.  

In  its  latest  comments  in  2019,  the  ILO  lifted  its  concerns  about  correctional  labour  as  a 
punishment  for  expressing  political  or  ideological  views  and  for  conduct  of  public  officials 
harmful to the state or other interests.  

Exposure  to  forced  labour  and  labour  exploitation  remains  closely  related  to  trafficking  in 
persons.  Armenian  labour  migrants  abroad  face  forced  labour,  often  following  recruitment 
fraud  and  exorbitant  recruitment  fees,  notably  in  Russia,  the  United  Arab  Emirates  (UAE), 
and Turkey. Armenian women and children are subjected to sex trafficking abroad and to sex 
and labour trafficking  and forced begging within Armenia. Children  working in  agriculture, 
construction, and service provision are vulnerable to labour trafficking. An increasing number 
of  Indian  migrants  who  willingly  seek  employment  in  the  informal  sector  in  Armenia  are 
reported  to  face  forced  labour18.  Armenia  was  downgraded  in  the  2018  US  Department's 
Trafficking in Persons Report as not fully meeting the minimum standards for the elimination 
of trafficking due to  less serious and sustained efforts  and maintained as Tier 2 in  the 2019 
Report. 

The impossibility of conducting workplace inspections, remains a key barrier to identifying, 
investigating  and  preventing  forced  labour.  In  addition,  the  fewer  prosecutions  and 
convictions of traffickers suggest a key shortcoming. Of the nine cases investigated in 2018, 
five  were  forced  labour  and  one  both  sex  trafficking  and  forced  labour.  Only  one  case  was 
prosecuted  and  no  trafficker  was  convicted.  Anti-trafficking  institutions  remain  in  place,  as 
well as a referral mechanism for victims. Action Plans are implemented, but regular reporting 
on  activities  and  results  is  lacking.  More  efforts  are  needed  to  identify  victims  of  forced 
labour,  including  training  of  officials  of  relevant  State  agencies,  and  better  cooperation 
between law enforcement bodies.  

Minimum Age for Work and Worst Forms of Child Labour (Conventions 138 
and 182) 

Poverty,    an  underlying  cause  of  child  labour,  significantly  decreased  in  the  last  years  but 
remains  high.  Child  poverty  reduction  was  a  priority  of  the  former  Government,  which  had 
launched a reform of the family benefit system as a main poverty reduction measure.  

Armenia does not feature on the latest US Department of Labour’s List of Goods Produced by 
Child  (or  Forced)  Labour.  Children  working  in  agriculture,  construction,  and  service 
provision  are  reported  to  be  vulnerable  to  labour  trafficking,  but  comprehensive  data  on 
child labour are lacking. The last national survey was conducted with the support of the ILO 
in 2015. The National Strategy on Child Rights Protection 2017-2021 and the corresponding 
Action Plan reflect the recommendations of the 2015 Child Labour survey.   

18 US, 2019 Trafficking Report 

14 

 
 
                                                 
There  was  no  change  in  child  labour  legislation  during  the  reporting  period.  A  major 
shortcoming  to  be  urgently  addressed  according  to  the  ILO  is  that  the  bulk  of  working 
children remains without legal protection since provisions in the Labour Code relating to child 
labour,  including  the  minimum  age  for  employment,  do  not  apply  to  work  performed 
outside  a formal  labour  relationship, such as unpaid work, work in the informal sector or 
self-employment.  

There  is  still  no  effective  mechanism  to  enforce  child  labour  legislation.  The  Health  and 
Labour Inspectorate remains without sufficient capacity in that respect and there is no other 
competent  agency.  Apart  from  a  dedicated  unit  within  the  police,  there  are  no  integrated 
systems in place to monitor child labour. 

Measures on the education side, if effectively implemented, could help curbing child labour. 
Longer compulsory education, until  the age of 19, has been in  force since September 2017. 
However,  there  is  no  information  about  the  necessary  enhancing  of  school  and  teaching 
capacities.  Projects  with  international  partners19 helped  making  the  education  system  more 
inclusive and reducing drop-outs, which can be an incentive to child labour. Armenia's limited 
capacity and resources to sustain the developed tools through its own means beyond funded 
projects is, however, an issue. 

Equal  Remuneration  and  Elimination  of  Discrimination  (Conventions  100 
and 111) 

The  gender  gap  in  labour  market  participation  and  employment  remain  high  at  around  20  
and  17  pp    respectively20,  also  reflecting  the  poor  job  opportunities  in  the  country  overall. 
Armenia  improved  its  ranking  in  the  2018  Global  Gender  Gap  index  to  98th  out  of  149 
countries, but still features among the lowest-ranked in Eastern Europe and Central Asia. The 
gender  pay  gap  remains  at  an  average  33.5%  and  even  higher  in  sectors  like  finance  and 
insurance or  IT. Efforts to address this issue, such as a gender-neutral job classification and 
remuneration system, remain concentrated in the public administration.  

The existing legislation (Labour Code and Law on Equal Rights and Equal Opportunities for 
women and men) still needs to be amended to rightly incorporate the principle of equal pay 
for  work  of  equal  value,  as  requested  by  the  ILO.  Equal  access  to  employment  and 
recruitment  is  not  well  covered  by  legislation.  Legislation  still  does  not  cover  sexual 
harassment in employment and occupation. 

The EU-funded OxYGen programme 
focuses  on  women’s  capacity  building 
for  a  gender  equality  agenda  and 
addresses  labour  rights,  gender-based 
discrimination  in  the  labour  market, 
and  gender  wage  disparities.  The  goal 
the 
this  programme,  part  of 
of 
INSPIRED+ GSP project, is to enable 
local  CSOs  to  create  a  road  map  for 
for 
ensuring  equal 
women and men in Armenia.  

labour 

rights 

June  2019,  defining 

Prohibition of discrimination had been enhanced 
by  the  amended  Constitution,  which  entered  in 
force in 2018. It was further strengthened by the 
introduction of a new article in the Labour Code 
in 
and  prohibiting 
discrimination in employment. Protected grounds 
are aligned with those in the Constitution and the 
new article specifically prohibits both direct and 
indirect  discrimination  at  all  stages  of  legal 
labour relations.  

19 https://www.unicef.org/armenia/en/what-we-do/education 
20 2018, World Bank Development Indicators, data 

15 

 
                                                 
The latest version of draft Law on Ensuring Equality was published in July 2019. The draft 
law  contains  a  comprehensive  definition  of  discrimination  and  prohibited  grounds  for 
discrimination,  as  well  as  the  responsibilities  of  employers  in  terms  of  preventing  and 
prohibiting  discrimination  in  the  workplace.  The  role  of  the  Equality  Council  tasked  with 
assisting  the  Human  Rights  Defender  with  implementation,  however,  would  be  only  an 
advisory  one  and  would  not  cover  the  private  sector. Discrimination  on  the  basis  of  sexual 
orientation is not covered by the draft Law on Equality and remains a highly sensitive issue. 

A  Draft  Strategy  and  Programme  of  Activities  for  Implementation  of  Policy  on  Ensuring 
Equal Rights and Equal Opportunities for Women and Men for 2019-2023 is being finalised. 
Before its submission to the Government, it is being checked to ensure that it is fully in line 
international  standards,  notably,  CEDAW  Concluding  Observations  and  UPR 
with 
Observations.  

In  practice,  most  discrimination  issues  identified  by  national  and  international  stakeholders 
relate  to  gender.  Women  reportedly  face  discrimination  at  every  stage  of  the  employment 
relationship.  Sexual  harassment  is  widespread  and  often  unreported.  Discrimination  in 
employment  and  occupation  is  also  reported  on  other  grounds  (age,  sexual  orientation, 
disabilities, and ethnicity)21. Mandatory employment quotas for people with disabilities were 
suspended for bigger public and private firms in May 2017. Discrimination on the ground of 
sexual orientation remains a highly sensitive issue. In a recent ranking on LGBTQI equality 
laws and practices in Europe, Armenia was ranked 47th of 49 countries (ILGA-Europe 2019). 
ILO  CEACR  underlined  the  need  for  proactive  measures  to  address  discrimination  between 
different ethnic groups in the labour market. 

Conclusions and priorities 

Progress has been limited, but the new government is engaging on key issues such as labour 
inspections  and  amending  the  Labour  Code  in  response  to  ILO  requests.  The  new  2019-23 
Decent  Work  Country  Programme  with  the  ILO  and  the  prolonged  EU  project  to  GSP+ 
implementation offer opportunities to advance on both issues.  

Re-establishing  a  fully-fledged  labour  inspection  system,  duly  mandated  and  empowered  in 
line  with  ILO  conventions  on  labour  inspections,  which  Armenia  has  ratified,  remains  an 
urgent matter. The impossibility to conduct inspections outside occupational health and safety 
is a major impediment to effective control of forced and child labour. More needs to be done 
to eliminate child labour and to guarantee that all working children, including those out of a 
formal  employment  relationship  can  benefit  from  the  protections  of  the  child  labour 
legislation. A roadmap has been developed with the ILO and work is starting on a legal basis 
for an extended mandate covering all labour rights, expected to be in place by end 2020. 

Amendments to the Labour Code on the prohibition of discrimination were a significant step, 
By providing  a broader legal basis to the prevention and protection against  discrimination, 
the adoption of the draft Law On Ensuring Equality would have an additional positive impact 
on the application of the ILO fundamental conventions N° 100 and 111.  

21 USDOS, 2018 Human Rights Report 

16 

 
                                                 
Further envisaged changes to the Labour Code remain essential to close the gaps identified 
by the ILO on the effective application of fundamental conventions in law. Adopting the draft 
law amending the Law on Trade Unions is needed to better guarantee freedom of association. 

The definition of forced labour in national legislation still needs to be brought in line with the 
ILO conventions and more efforts are needed to  curb the risks  of  forced  labour and labour 
exploitation for economic migrants to and from Armenia. 

4.3  UN  Conventions  on  Environmental  Protection  and  Climate   

Change  

Convention on International Trade in Endangered Species of Wild Flora and 
Fauna (CITES) 

Armenia's  national  legislation  related  to  the  implementation  of  CITES  remains  ranked  as 
Category  3,  which  means  that  it  does  not  meet  the  requirements  for  the  Convention's 
implementation.  Some  CITES  legislation  is  in  place,  and  some  provisions  have  been 
translated  and  submitted  to  the  Secretariat  as  of  September  2018.  Once  provisions  are  fully 
submitted, the Government and the Secretariat are to agree on the legislative analysis, and the 
possibility for reaching Category 1 status. 

The Armenian authorities have taken some steps to address the four minimum requirements 
set  by  the  CITES  secretariat.  A  Management  and  Scientific  Authority,  respectively  the 
Ministry of Nature Protection and the Interagency Council, have been appointed  since 2008. 
The  government  envisages  the  full  establishment  of  the  Interagency  Council  by  the  end  of 
2019.  Trade  in  specimens  in  violation  of  CITES  is  prohibited  by  the  Law  On  Fauna  and 
amendments to the Code of Administrative Offences. Penalties for such trade are covered in 
the  legislation  on  administrative  and  environmental  offences,  as  well  as  the  Customs  Code. 
The  current  level  of  fines  is  low  and  is  unlikely  to  have  dissuasive  impact  for  potential 
offenders. The final  requirement of CITES  is  on the seizure of illegally traded or possessed 
specimens. A draft Article to this effect in the Criminal Code has not yet been adopted.  

During  2018,  Armenian  authorities  actively  worked  with  the  CITES  Secretariat  on  the 
introduction of the electronic CITES permit system, which will improve the transparency of 
the  process,  reduce  corruption  risks,  illicit  trade  of  wildlife,  and  facilitate  the  exchange  of 
information  between management, scientific  authorities and business  entities. Regarding the 
issuing of CITES permits in electronic format, it should be mentioned that the RA Customs 
Service no longer works with the Automated System for Customs Data (ASYCUDA).  

Basel Convention 

Over the reporting period, no salient shortcomings regarding the implementation of the Basel 
Convention were identified22.  

Convention on Biological Diversity (CBD) 

Due  to  delays  in  the  submission  of  Armenia’s  Sixth  National  Report  under  CBD,  no 
significant  updates  on  implementation  are  available.  Currently,  the  two  main  policy 
documents in the area of biodiversity are the revised National Strategy and Action Plan on the 

22 For details, please refer to the biennial report for 2016-2017, SWD(2018) 32 final of 19.1.2018 

17 

 
 
 
                                                 
Conservation,  Protection,  Reproduction  and  Use  of  Biological  Diversity,  and  its  associated 
Action  Plan  for  2016-2020,  as  well  as  the  Strategy  of  the  Republic  of  Armenia  for  Special 
Protected  Nature  Areas  and  the  State  Programme  for  Protection  and  Usage,  adopted  in 
September 2014.   

The  Caucusus  is  considered  among  the  world’s  most  endangered  biodiversity  hotspots.  The 
main  pressures  to  biodiverity  in  Armenia  are  related  to  the  development  of  industry, 
agriculture,  urbanization,  and  exploitation  of  forests  and  grasslands.  Armenia  has  set  up 
specially  protected  areas  covering  70%  of  the  country’s  flora  and  fauna,  as  well  as  special 
strategies for particular species, such as the Armenian moufflon, bezoar goat, and panther.  

Stockholm Convention on Persistent Organic Pollutants (POPs) 

Armenia submitted an update to its National Implementation Plan (NIP), addressing the Fifth 
Conference  of  the  Parties  (COP  5)  amendments,  on  23  April  2018.  According  to  the 
government, the updated NIPs with new POPs listed in Stockholm Convention COP 6 (due in 
2016)  and  COP  7  (due  in  2018)  were  under  finalisation,  but  have  not  been  submitted  to 
Secretariat yet.  

A  pilot  project  (2016-2018)  on  the  Reduction  of 
Unintentional  Organic  Pollutants  Releases  (U-
POPs) from Open Burning Sources aimed to reduce 
the  releases  of  dioxins  and  furans  while  renovating  a 
selected landfill.  

The  government  prepared  and 
approved a Concept of Republic 
of  Armenia  Law  on  Chemicals 
in  November  2018.  The  draft 
Law  on  Chemicals  will  be 
submitted  to  the  Government  of 
RA in 2020.  

on 

Another  project,  Elimination  of  Obsolete  Pesticide 
Stockpiles  and  Addressing  POPs  Contaminated 
Sites  within  a  Sound  Chemicals  Management 
Framework  in  Armenia  (ending  in  2019)  aims  to 
eliminate  obsolete  pesticides  and  liquidation  from  the 
Nubarashen burial site.  

effective 
Constraints 
implementation  include  the  lack 
of  education  in  the  refrigeration 
industry, 
and  air-conditioning 
which  may  be  a  barrier  to  the 
introduction  of  new  ozone  and  climate  friendly  technologies.  Additionally,  customs  entry 
points  are  not  equipped  with  Ozone-Depleting  Substances  (ODS)  identifiers  to  allow  field-
testing to distinguish between ODS and non-ODS refrigerants. 

Cartagena Protocol on Biosafety 

A  draft  Law  On  Genetically  modified  organisms  (GMO)  along  with  the  package  of  other 
related laws23 was finalised and made public on 4 September 201824. The Law’s main purpose 
is  to  provide  regulations  for  the  usage  of  GMOs  and  to  ensure  biosafety25.  Among  other 
regulations, the Draft Law: (i) provides for definition of GMOs and related concepts; (ii) sets 
for the main principles of GMO regulation and utilization; (iii) use of GMOs for agricultural 
purposes;  (iv)  prohibition  and  prevention  of  illegal  utilization  of  GMOs.  Under  the  new 
government, the  relevant ministries reported drafting a National Law regarding Biosafety of 
Genetically Modified Organisms to be submitted to the National Assembly.  

23  https://www.e-draft.am/projects/1178/about 
24 https://www.e-draft.am/projects/1178 
25 https://www.e-draft.am/projects/1178/about 

18 

 
 
 
                                                 
 
Article 285 of the  Draft  amendments  to  the Code on Administrative Offences prohibits  and 
provides  for  administrative  liability  for  the  violation  of  the  rules  biosafety  in  utilization  of 
GMOs,  in  the  form  of  fines.  These  lenient  penalties  are  not  expected  to  have  a  substantial 
preventative effect, in particular taking into account the benefits of the illegal use of GMOs.   

Conventions on Climate Change 

The  main  constraints  pertaining  to  the  implementation  of  the  United  Nations  Framework 
Convention  on  Climate  Change  (UNFCCC),  as  raised  by  Armenia  in  their  Second  Biennial 
Update Report from May 2018, are dependence on external financing, shortage and frequent 
rotation of qualified specialists with knowledge of the Convention, as well as low awareness 
of the Convention at local/regional level. The authorities planned to complile Armenia’s draft 
4th  National  Communication  by  the  end  of  2019,  though  still  outstanding.  A  EU4Climate 
regional  project  plans 
to  develop  a  Nationally  Determined  Contributions  (NDC) 
implementation roadmap by October 2020.  

In  February  2017,  Armenia  ratified  the  Paris  Agreement  of  the  UNFCCC,  and  the  Doha 
amendment to the Kyoto Protocol.   

As  for  the  Montreal  Protocol,  Armenia  continues  phasing  out  hydrochlorofluorocarbons 
(HCFCs). Stage II of the HCFC Phase-out Management Plan covers the period of 2016-2020. 
This  should  enable  Armenia  to  meet  its  obligations  under  the  Montreal  Protocol  on  the 
accelerated phase-out of HCFCs and will effectively target reaching 35% phase-out of HCFCs 
by 2020. The phase-out  plan covers legislative changes, improving facilities at  refrigaration 
and  air-conditioning  training  institutions  and  customs,  and  technical  assistance  and 
refrigeration technicians.  

Armenia  ratified  the  Kigali  Amendment  to  the  Montreal  Protocol  in  May  2019,  adding 
powerful greenhouse gases HCFCs to the list of substances controlled under the Protocol. 

Conclusions and priorities 

The ratification of the Kigali Amendment to the Montreal Protocol in 2019, in addition to the 
Paris Agreement and Doha amendment in 2017, signals Armenia’s continued commitment to 
international environmental standards. Furthermore, the authorities reported some progress 
in aligning national legislation with CITES requirements, but more needs to be done. 

Concerns  remain  around  low  penalty  amounts  for  violations  of  CITES  and  the  Cartagena 
Protocol,  which  are  not  expected  to  have  a  serious  deterrent  effect.  Challenges  persist  in 
terms of capacity and financing. 

4.4  UN Conventions on Good Governance  

International Drug Control Conventions 

The  International  Narcotics Control Board  (INCB) undertook  a mission  to  Armenia in  June 
2018. The INCB reports increased cannabis seizures and a decline in cannabis resin seizures 
for  2013-2017  in  the  Southern  Caucusus  region,  which  Armenia  is  a  part  of.  Armenia 
continued  to  seize  increasing  amounts  of  methamphetamine  in  2017,  trafficked  into  the 

19 

 
country mainy from Iran. A high prevalence of opiate use was noted26. The 2018 INCB report 
does  not  comment  on  Armenia’s  implementation  status,  after  considerable  improvement 
efforts noted in 2015, including the 2016 Law on Drugs and other drug control reforms. 

Armenia has, in recent  years, reported a rise in seizures of narcotic drugs including cocaine, 
opium and cannabis resin, which may indicate that the country is increasingly being targeted 
for transit. While illicit drug use in the country is thought to be moderate, its exact extent is 
difficult to gauge in the light of the limited epidemiological data available. 

In  terms  of  regional  cooperation,  Armenia  is  a  part  of  the  Collective  Security  Treaty 
Organisation  (along  with  Belarus,  Kazakhstan,  Kyrgyzstan,  the  Russian  Federation,  and 
Tajikistan),  which  carried  out  two  large-scale  joint  operations  in  2017  to  counter  drug-
trafficking. Armenia also participated in a regional workshop on joint investigation teams and 
controlled deliveries in February – March 2018.  

UN Convention against Corruption (UNCAC) 

While the fight against corruption has become a priority for the Armenian Government in the 
past years and important legislative and policy developments are taking place, shortcomings 
remain  and  the  public  perception  of  corruption  in  the  country  remains  negative.  The  last 
UNCAC  review  from  2015  noted  a  need  for  closer  alignment  of  Armenian  legislation  with 
some  principles  and  definitions  of  the  Convention.  On  the  other  hand,  UNCAC  reviewing 
experts  highlighted  some  legal  provisions  as  good  practice,  including  the  aim  to  expedite 
international cooperation and mutual legal assistance. 

Armenia’s  ranking    in  the  2018  Transparency  International  Corruption  Perception  Index 
improved to 105 out of 176 countries (from 113th place). There was  a slight improvement of 
perceived level of public sector corruption score at 35 out of 100 (where zero means 'highly 
corrupt') in 2017-8, compared to 33 in 2016.  

There  were  several  legislative  changes  in  the  previous  reporting  period,  such  as  the 
criminalisation  of  illicit  enrichment  and  an  anti-corruption  package  including  a  Law  on  the 
Corruption Prevention Commission, the Law on Making Amendments in the Law on Public 
Service and the Law on Whistleblowing System. The package was to enter into effect in early 
2018.  The  preliminary  assessment  of  the  package  was  positive,  but  concerns  remain,  for 
example regarding the selection process of the board members of the Corruption Prevention 
Commission; and the extension of the coverage of the declaration of income obligations for 
civil servants.  

Corruption  prevention  is  among  the  top  priorities  of  the  new  government27.  The  authorities 
adopted  a  new  Anti-Corruption  Strategy  (2019-2021)  with  the  intention  to  set  up  the 
Corruption Prevention Commission as an independent anti-corruption body. On 21 May 2019, 
the  official  page  for  the  Integrated  Whistle-blower  platform  (www.azdararir.am)  was 
launched with participation of the high-level governmental officials from the Prime Minister's 
Office, Prosecutor General's Office, and Ministry of Justice. 

26https://www.incb.org/documents/Publications/AnnualReports/AR2018/Annual_Report_Chapters/05_Chapter_
III_Annual_Report_2018_E_.pdf 
27 http://www.primeminister.am/en/press-release/item/2018/05/18/Prime-Minister-Nikol-Pashinyan-introduced-
SRC-chairman/. 

20 

 
                                                 
In 2018, 409 criminal cases of corruption and official nature were investigated by the Special 
Investigation Service.  According to  the Prosecutor General  Office of RA,  during 2018, 960 
persons were prosecuted on corruption cases investigated by the bodies of inquiry from which 
470  were  officials.  There  are  several  high-profile  criminal  cases  on  corruption  involving 
members  of  the  previous  government.  Those  include  the  former  President  of  Armenia,  Mr 
Rober Kocharian and co-defendants, charged with overthrowing constitutional order in 201828 
and  in  2019  for  taking  a  bribe  in  the  amount  of  3  million  USD29.  The  former  Chief  of  the 
Army  Headquarters  General  Yuri  Khachaturov  and  former  Minister  of  Defense  General 
Seyran Ohanian were charged for overthrowing the constitutional order; the former Chief of 
Staff of the Kocharian’s Presidential Office, Armen Gevorgian was charged for assisting the 
bribery. The Prosecutor’s Office approved the indictment and sent it to court in April 2019. 
Other  cases  include  former  Minister  of  Environment  Aram  Harutyunyan,  wanted  under 
charges of taking a bribe of 14 million USD from a business woman Silva Hambardzumya for 
not hindering her investment operations in the mining business30.   

The  prevention  of  money-laundering  is  closely  related  to  the  fight  against  corruption  as 
corruption  represents  one  of  the  main  predicate  offences  in  connection  with  the  illicit 
laundering  of  proceeds  in  the  context  of  Armenia.  Armenia  has  made  good  and  steady 
progress in strengthening its legal framework in relation to anti-money laundering as well as 
counter-terrorist  financing  and  its  effective  implementation  in  the  recent  years.  Some 
deficiencies  remain  and  should  be  further  mitigated.  For  instance,  domestic  politically 
exposed  persons  and  their  family  members  and  associates  are  not  subject  to  specific 
enhanced customer due diligence requirements. Law enforcement authorities should continue 
to  increase  their  efforts  to  pursue  money  laundering  and  seize  criminal  proceeds  in  line  the 
risks faced by the country.  

Conclusions and priorities 

Armenia  is  on  track  with  fulfilling  its  obligations  under  international  drug  control 
conventions.  

The fight against corruption has been highlighted by the new government as one of its main 

policy  priorities.  A  new  Anti-corruption  Strategy  for  2019-2021  and its  Action  Plan  were 
adopted.  The  establishment  of  an  independent  corruption  prevention  body  with  operative-
investigative  functions,  the  Commission  for  Prevention  of  Corruption,  is  underway. 
Furthermore,  Armenia  has  made  good  and  steady  progress  in  strengthening  its  legal 
framework in relation to anti-money laundering as well as counter-terrorist financing and its 
effective implementation in the recent years.  

28 https://www.rferl.org/a/former-armenian-president-kocharian-charged-with-bribe-taking/29767678.html 
29  https://www.azatutyun.am/a/29909924.html 
30 Hambartsumian told RFE/RL in October that she had to pay a USD14 million bribe in 2008 to then-
Environment Minister Aram Harutyunian. 

21 

 
                                                 
ANNEX 

Armenia – Treaty Ratification and Reporting 

Convention 

Status of ratification / 
reservations31 

Compliance with reporting obligations to monitoring bodies 

1. Convention on the 
Prevention and Punishment of 
the Crime of Genocide 

2. International Convention on 
the Elimination of All Forms of 
Racial Discrimination 

Accession: 23.06.1993 

No reporting obligations 

No reservations 

Accession: 23.06.1993 

Compliant with reporting obligations 

No reservations 

Last report submitted on 29.12.2015. 

Last concluding observations from 31.05.2017. 

Last follow-up state party report submitted on 31.08.2018. 

Next report due by  23.07.2020. 

3. International Covenant on 
Civil and Political Rights 

Accession: 23.06.1993 

Compliant with reporting obligations 

No reservations 

Last report submitted on 08.07.2019. 

Last concluding observations from 31.08.2012. 

Last follow-up state party report submitted on 11.04.2016. 

4. International Covenant on 
Economic, Social and Cultural 
Rights 

Accession: 13.09.1993 

Lack of compliance with reporting obligations 

No reservations 

Last report submitted on 16.07.2011.  

Last concluding observations from 15.07.2014. 

Latest report was due by 30.05.2019. 

5. Convention on the 
Elimination of All Forms of 
Discrimination against Women 

Accession: 13.09.1993 

Compliant with reporting obligations 

No reservations 

Last report submitted on 11.03.2015. 

Last concluding observations from 18.11.2016. 

Last follow-up state party report submitted on 10.06.2019. 

Next report due by  30.11.2020. 

6. Convention against Torture 
and other Cruel, Inhuman or 
Degrading Treatment or 
Punishment 

Accession: 13.09.1993 

Compliant with reporting obligations 

No reservations 

Last report submitted on 24.06.2015. 

Last concluding observations from 07.12.2016. 

Last follow-up state party report submitted on 20.08.2018. 

Next report due by 07.12.2020. 

7. Convention on the Rights of 
the Child 

Accession: 23.06.1993  

Lack of compliance with reporting obligations 

No reservations 

Last report submitted on 04.02.2010. 

8. Convention concerning 
Forced or Compulsory Labour, 

Ratification: 2004 

Compliant with reporting obligations 

Latest CEACR32 comments: Direct Request 2018. 

Last concluding observations from 08.07.2013. 

Latest report was due by 22.01.2019. 

31 Reservations do not apply in the ILO system, so there is no relevance to providing information on reservations 
under each of these conventions. 

22 

 
 
 
 
                                                 
No. 29 

Next report due in 2020.  

9. Convention concerning 
Freedom of Association and 
Protection of the Right to 
Organise, No. 87 

10. Convention concerning the 
Application of the Principles of 
the Right to Organise and to 
Bargain Collectively, No. 98 

11. Convention concerning 
Equal Remuneration of Men 
and Women Workers for Work 
of Equal Value, No. 100 

12. Convention concerning the 
Abolition of Forced Labour, 
No. 105 

13. Convention concerning 
Discrimination in Respect of 
Employment and Occupation, 
No. 111 

14. Convention concerning 
Minimum Age for Admission 
to Employment, No. 138 

15. Convention concerning 
Minimum Age for Admission 
to Employment, No. 182 

Ratification: 2006 

Compliant with reporting obligations 

Latest CEACR comments: Direct Request 2016. 

Last report received in 2019. 

Next report due in 2022.  

Ratification: 2003 

Compliant with reporting obligations 

Latest CEACR comments: Direct Request 2016. 

Last report received in 2019. 

Next report due in 2022.  

Ratification: 1994 

Compliant with reporting obligations 

Latest CEACR comments: Observation 2016; Direct Request 
2016. 

Last report following comments received 26.09.2018. 

Next report due in 2021.  

Ratification: 2004 

Compliant with reporting obligations 

Latest CEACR comments: 2019 replies received do not raise 
further comments.  

Next report due in 2020.  

Ratification: 1994 

Compliant with reporting obligations 

Latest CEACR comments: Direct Request 2016. 

Last report following comments received 26.09.2018. 

Next report due in 2021. 

Ratification: 2006 

Compliant with reporting obligations 

Latest CEACR comments: Direct Request 2018. 

Next report due in 2020.  

Ratification: 2006 

Compliant with reporting obligations 

Latest CEACR comments: Direct Request 2018. 

Next report due in 2020. 

16. CITES 

Accession: 10.04.2008 

Lack of compliance with reporting obligations 

No reservations 

Last Annual Report (2016) submitted on 01.11.2017. 

Annual Reports for 2017, 2018 due. 

Last Biennial Report33 (2009-2010) submitted on 19.07.2012. 

Biennial Reports for 2011-12, 2013-14, and implementation34 
report for 2015-2017 due.  

Annual Illegal Trade report for 2017 due. 

17. Montreal Protocol 

Accession: 01.10.1999 

Compliant with reporting obligations 

32 ILO Committee of Experts on the Application of Contentions and Recommendations 
33 Mandatory but not subject to compliance procedures. 
34 Implementation reports (formally biennial reports) are mandatory, but not subject to compliance procedures.  

23 

 
 
 
 
 
 
 
                                                                                                                                                         
No reservations 

Most recent annual data for 2016 was submitted.  

No more recent reporting data is available.  

18. Basel Convention 

Accession: 01.10.1999 

Compliant with reporting obligations 

No reservations 

Last (2017) National Report submitted on 28.12.2018. 

National Report (2012) submitted on 26.02.2018. 

National report (2005) submitted on 27.02.2018. 

No data on 2018 Annual National Report available. 

19. Convention on Biological 
Diversity 

Accession: 14.05.1993 

Compliant with reporting obligations 

No reservations 

Next (Sixth) National Report submitted offline.  

Revised National Biodiversity Strategy and Action Plan 
submitted on 02.11.2016. 

20. UN Framework Convention 
on Climate Change 

Accession: 14.05.1993 

Compliant with reporting obligations 

No reservations 

Last (Second) Biennial Update Report submitted on 05.05.2018 

Next Biennial Update Report due by Dec. 2020 

Latest (Third) National Communication submitted on 
22.04.2015.  

21. Cartagena Protocol on 
Biosafety 

Accession: 30.04.2004   

Compliant with reporting obligations 

No reservations 

Last (Third) national report submitted on 03.04.18. 

Next (Fourth) National report due on 01.09.2019 

22. Stockholm Convention 

Accession: 26.11.2003  

Compliant with reporting obligations 

No reservations 

Latest (Fourth) National Report submitted on 10.08.2018. 

23. Kyoto Protocol 

Accession: 25.04.2003 

No reporting obligations 

24. UN Single Convention on 
Narcotic Drugs 

25. UN Convention on 
Psychotropic Substances 

No reservations 

Accession: 13.09.1993 

No reservations 

Reviewing is fulfilled by the International Narcotics Control 
Board (INCB). 

Accession: 13.09.1993 

INCB mission took place 25-28 June 2018.  

No reservations 

26. UN Convention against 
Illicit Traffic in Narcotic Drugs 
and Psychotropic Substances 

Accession: 13.09.1993 

No reservations 

27. UN Convention against 
Corruption 

Accession: 08.03.2007 

No reservations 

Reviewing is fulfilled by the UN Office on Drugs and Crime 
(UNODC). 

Latest UNODC review executive summary and UNODC Country 
review for the cycle 2010 – 2015 published on 06.03.2015.  

Second review cycle 2015-2020.  

24