A/HRC/17/33 minimum age of employment, apprenticeship and training, membership of trade unions, accommodation, social security, access to health services, etc.), and would make these groups less vulnerable to xenophobia or racism in politics and in the wider society. 2. Noncitizen voting rights: a global issue 71. The Special Rapporteur recalls that the anomaly of foreign non-citizens living in democratic host countries without political rights has long been viewed as problematic. As previously discussed, naturalization rules and practices vary from State to State, and in some places immigrants have little chance of becoming citizens due to a variety of factors. As a result, countries of destination have had to devise policies and institutions to respond to the problems of increased ethnic diversity.33 The central issues are: defining who is a citizen, how newcomers can become citizens and what citizenship means. In principle the nation State only allows a single membership, but migrants and their descendants have a relationship to more than one State. They may be citizens of two States, or they may be a citizen of one State and live in another. Thus large-scale settlement inevitably leads to a debate on citizenship.34 72. The first concern for migrants is not the exact content of citizenship, but how they can obtain it, in order to achieve a legal status formally equal to that of other citizens. Access to citizenship varies in different countries, depending on the prevailing concept of nationhood. The Special Rapporteur recalls different types of models which define citizenship: (a) The imperial model. In this model, the definition of belonging to the nation is defined as being a subject of the same power or ruler. This model allowed the integration of the various peoples of multi-ethnic empires (British, Austro-Hungarian, Ottoman, etc.), and remained formally in operation in the United Kingdom until the Nationality Act of 1981,35 which created a modern type of citizenship for the first time. The concept almost always has an ideological character, in that it helps to obscure the actual dominance of a particular ethnic group or nationality over the other subject peoples; (b) The ethnic model. The definition of belonging to the nation is asserted in terms of ethnicity (common descent, language and culture), which often means exclusion of minorities from citizenship and from the community of the nation; (c) The republican model. The definition of the nation is that of a political community, on the grounds of a constitution, laws and citizenship, with the possibility of admitting newcomers to the community. This approach dates back to the French and American revolutions. France is the most obvious current example. (d) The multicultural model. Here the nation is also defined as a political community, based on a constitution, laws and citizenship that can admit newcomers. However, in this model newcomers can maintain their distinctive cultures and form ethnic communities, providing they conform to the basic national laws. This pluralist or multicultural approach became dominant in the 1970s and 1980s in Australia, Canada and Sweden, and was also influential in other West European countries. 33 34 35 18 See in particular Citizenship Policies for an Age of Migration, T. Alexander Aleinikoff and Douglas Klusmeyer, 2001. See note 5 above, p. 44. Available at: http://www.statutelaw.gov.uk/content.aspx?&parentActiveTextDocId=1360590&ActiveTextDocId=1 360658.