A/HRC/41/54/Add.2 of domestic law on or after exit day”.20 The Special Rapporteur stresses that the exit of the United Kingdom from the European Union must not result in lower levels of human rights protection and that the Government should not roll back on human rights standards derived from European Union legislation. B. Policy and institutional framework 12. During her visit, the Special Rapporteur learned about various policy documents that are relevant for the promotion of human rights, equality, non-discrimination and tolerance, including the Integrated Communities Action Plan, the Hate Crime Action Plan 2016–2020, the Hate Crime Strategy 2017–2020 of the Crown Prosecution Service, the Race Equality Framework for Scotland 2016–2030, the Race Equality Action Plan 2017–2021 for Scotland, the New Scots Refugee Integration Strategy 2018–2022, the Race Equality Strategy 2015–2025 for Northern Ireland, and the Strategic Equality Plan 2016–2020 and associated Equality Objectives for Wales. 13. While these policies are important developments, the United Kingdom still has not adopted a country-wide strategy or action plan that addresses racial discrimination and inequality in a comprehensive fashion, as recommended by the Committee on the Elimination of Racial Discrimination (CERD/C/GBR/CO/18-20, para. 17, and CERD/C/GBR/CO/21-2, paras. 14 (b), 23 and 25 (a)). Instead, the current approach appears to be one of fragmented strategies whereby departments and devolved nations work in silos. The Equality and Human Rights Commission has highlighted the shortcomings of such an approach, emphasizing that sustainable solutions can only be found through a coordinated cross-sectoral strategy that recognizes the interrelationship of racial discrimination in various areas of life. For example, the Commission notes that progress in reducing the employment gap for ethnic minorities requires concrete measures to address the educational attainment gap.21 14. Furthermore, civil society has highlighted the need for concrete targets, measurable outcomes, adequate resources, clear timelines and accountability structures to ensure the effective implementation and evaluation of anti-discrimination policies. With regard to Northern Irish Race Equality Strategy, for example, interlocutors raised concerns about the absence of an accompanying action plan that would allow for a meaningful assessment and evaluation of measures taken. 15. During consultations, civil society has also expressed grave concern about the decision taken by the Government in 2012 to make equality impact assessments discretionary.22 For example, reports show that neither the emergency 2010 budget nor the 2017 budget contained any provisions for equality impact assessments, although both budgets contained austerity measures that have been shown disproportionately to affect Black and minority ethnic communities, women especially. 23 The Special Rapporteur shares civil society’s and racial and ethnic minority communities’ concerns relating to equality impact assessments. The non-mandatory nature of these assessments in the United Kingdom undermines pursuit of racial equality in too many sectors of British life. The intent of legislators, policymakers and those tasked with implementation cannot on its own be relied upon to ensure that formal commitments to racial equality are upheld. As mentioned above, well-meaning laws and policies can have racially discriminatory effects. The foreseeable disparate impact of policies and their implementation on minority groups requires independent analysis and review even prior to their adoption. 20 21 22 23 See https://publications.parliament.uk/pa/bills/lbill/2017-2019/0079/18079.pdf, art. 5 (4), and www.equalityhumanrights.com/en/what-are-human-rights/how-are-your-rights-protected/whatcharter-fundamental-rights-european-union-0. www.equalityhumanrights.com/en/publication-download/healing-divided-britain-needcomprehensive-race-equality-strategy, pp.11–13. www.bbc.co.uk/news/uk-politics-20400747. www.intersecting-inequalities.com/copy-of-report, p. 7. 5