Udenrigsudvalget 2023-24
URU Alm.del Bilag 169
Offentligt
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FINAL REPORT FOR THE
UNITED NATIONS SECRETARY-GENERAL
Independent Review of Mechanisms and Procedures
to Ensure Adherence by UNRWA to
the Humanitarian Principle of Neutrality
20 APRIL 2024
 URU, Alm.del - 2023-24 - Bilag 169: Uafhængig undersøgelse af mekanismer og procedurer, der skal sikre, at UNRWA overholder humanitære neutralitetsprincipper
Table of contents
I.
II.
III.
IV.
Executive Summary
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Engagement with donors
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Governance
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Management and oversight mechanisms
Management
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Internal oversight
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Reporting and intake of allegations
Investigations
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Disciplinary mechanism: the UNRWA Dispute Tribunal
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14
UNRWA property, procurement and project oversight
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V.
Neutrality of staff
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Regulatory Framework
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Screening and vetting
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Training
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Staff care
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36
Endnotes
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43
Annexes
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46
Annex A: Terms of Reference
�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½�½
46
Annex B: Overview of documented and alleged violations of neutrality and inviolability
�½�½�½�½�½�½�½�½�½�½�½�½�½�½
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I. Executive summary
An Independent Review Group on the  UN  Relief  and Works Agency for
Palestine Refugees in the Near East (UNRWA) was appointed by the
United Nations (UN) Secretary-General, in consultation with the UNRWA
Commissioner-General, on 5 February 2024. The Group was created to as-
sess whether UNRWA is doing everything within its power to ensure neu-
trality and respond to allegations of serious neutrality breaches when they
are made, taking into account the […] context in which it has to work, espe-
cially in Gaza,
1
and to make recommendations for UNRWA to improve and
strengthen in this area, if necessary. This followed allegations made by the
Government of Israel in January 2024 that some UNRWA staff may have
participated in the 7 October 2023 terror attacks on Israel. The UN Secre-
tary-General also activated a separate investigation by the UN’s Office of
Internal Oversight Services (OIOS) to determine the veracity of these allega-
tions, which, if proven true, would be horrifying in addition to being a grave
violation of their obligations towards the Organization.
In the days and weeks after the allegations, 16 Member State donors sus-
pended or paused funding, and others indicated conditionality. Overall, the
suspension of funding amounted to around US$450 million. Based on ini-
tiatives already taken by UNRWA, a number of Member States have since
resumed funding. However, Member States requested more information on
what had occurred as well as reinforcement of UNRWA’s existing neutrality
mechanisms and procedures, including staff vetting and oversight. 
The Review Group commenced its work on 13 February 2024. Led by Ms.
Catherine Colonna, the Group included three research organizations, name-
ly the Raoul Wallenberg Institute of Human Rights and Humanitarian Law
in Sweden, the Chr. Michelsen Institute in Norway, and the Danish Institute
for Human Rights.
Throughout the nine-week review, the Group extensively analysed the mech-
anisms and procedures currently in place within UNRWA to ensure neu-
trality and address potential breaches. The Group’s members conducted
field visits to UNRWA headquarters and facilities in Amman, Jerusalem and
the West Bank, engaging with various stakeholders including UNRWA offi-
cials, donor Member States, host countries, Israel, the Palestinian Authority,
Egypt, UN agencies and non-governmental organizations (NGOs). The Group
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conducted meetings and interviews with more than 200 people, including
with UNRWA staff in Gaza. Direct contacts were made with 47 countries and
organizations.
The three institutes submitted their research to the Secretary-General through
his Chef de Cabinet and to the Chair. The present document, which consti-
tutes the final review report, is presented under the responsibility of the Chair.
Situating the review, it is significant that UNRWA continuously operates amid
recurring conflicts, violence, a lack of political progress, poor socioeconomic
conditions and the proliferation of armed groups. In Gaza in particular, Ha-
mas, the de facto ruling entity until October 2023, is designated as a terrorist
organization by major donors such as the United States and the European
Union (EU), while other factions also actively oppose the Palestinian Author-
ity. UNRWA’s neutrality challenges differ from those of other international
organizations due to the magnitude of its operations, with most personnel
being locally recruited and recipients of UNRWA services.
In the absence of a political solution between Israel and the Palestinians,
UNRWA remains pivotal in providing life-saving humanitarian aid and essen-
tial social services, particularly in health and education, to Palestinian refu-
gees in Gaza, Jordan, Lebanon, Syria and the West Bank. As such, UNRWA is
irreplaceable and indispensable to Palestinians’ human and economic devel-
opment. In addition, many view UNRWA as a humanitarian lifeline.
As a UN agency, UNRWA and its staff and personnel have a fundamental
obligation to maintain neutrality to ensure the integrity of the agency’s mis-
sion and the effectiveness of its operations. Neutrality is a UN commitment
as one of the four humanitarian principles formally adopted by the General
Assembly
1
and upheld by other UN agencies while operating in humanitarian
settings. It means that humanitarian actors must not take sides in hostilities
or engage in controversies of a political, racial, religious or ideological na-
ture. Despite significant investment and efforts, UNRWA’s neutrality has been
consistently questioned by Palestinian and Israeli stakeholders. In the past,
several allegations of neutrality breaches have taken place and disciplinary
measures were taken, but allegations of neutrality breaches were never as
serious as the ones that surfaced in January 2024.
The Review revealed that UNRWA has established a significant number of
mechanisms and procedures to ensure compliance with the humanitarian
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principles, with emphasis on the principle of neutrality, and that it possesses
a more developed approach to neutrality than other similar UN or NGO enti-
ties. The UNRWA Neutrality Framework was established in 2017 “to serve as
a repository of existing standards, practices and procedures with regard to
neutrality and to introduce new standards and procedures.”
3
The framework
aims to “ensure a consistent and coherent approach, agency-wide, to key is-
sues relating to the neutrality of UNRWA operations.”
4
The Framework covers
substantive areas including the neutrality of UNRWA staff and other person-
nel, including their use of social media; neutrality of UNRWA installations;
neutrality of UNRWA assets, particularly vehicles; and other areas in relation
to UNRWA operations, including donors, partners and agency assistance.
Obligations for the agency’s staff are set out clearly in the International Staff
Regulations and the Area Staff Regulations dated 1 January 2018.
Despite this robust framework, neutrality-related issues persist. They include
instances of staff publicly expressing political views, host-country textbooks
with problematic content being used in some UNRWA schools, and politi-
cized staff unions making threats against UNRWA management and caus-
ing operational disruptions. The Review identified several measures to help
UNRWA address its neutrality challenges in eight critical areas requiring im-
mediate improvement:
•
Engagement with donors
•
Governance
•
Management and internal oversight structures
•
Neutrality of staff and behaviour
•
Neutrality of installations
•
Neutrality of education
•
Neutrality of staff unions
•
Strengthened partnership with UN agencies
The measures identified in each critical area are designed to help UNRWA
face the neutrality challenges stemming from the operational, political and
security environment in which it operates. Given the uniqueness of this po-
litical context, these measures will have a significant impact only with the
support of host countries, Israel and the Palestinian Authority.
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II. Engagement with donors
Donors expressed significant concerns over UNRWA’s lack of  communi-
cation and information-sharing. This has focused not only on the agen-
cy’s neutrality issues but also on, for example, its budget and its financial
state. UNRWA’s communication efforts on neutrality are perceived as too
defensive and lacking transparency.
UNRWA uses a number of forums and channels to inform donors. However,
decision makers in donor capitals often feel that the information shared
by UNRWA does not meet their needs. Donors require regular updates on
UNRWA’s financial status, the impact of the lack of funds on operations,
and realistic evidence-based predictions on when the funding shortfall will
take effect.
The relationship with donors needs to be deemed a strategic partnership,
including on the issue of neutrality. For this, transparency is crucial. UNRWA
should engage donors early with neutrality concerns and provide greater
financial transparency to restore trust and confidence in the organization.
The Chair recommends to:
1.
Increase the frequency and strengthen the transparency of
UNRWA’s communication with donors on its financial situa-
tion and on neutrality allegations and breaches;
a. Plan regular updates by UNRWA on its budget and the
structure of this budget, including in the Commission-
er-General’s direct interactions with Governments.
b. Establish ‘Integrity Briefings’ for donors interested in
supporting UNRWA on integrity and related issues, with
meetings or briefings held at UN headquarters in New
York or Geneva.
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III. Governance
UNRWA was established by resolution 302 (IV), adopted by the UN General
Assembly (UNGA) on 8 December 1949. The agency is therefore formally
mandated by the UNGA, which gives the organization its political support
at its mandate renewal every three years. The UNRWA Commissioner-Gen-
eral, who reports directly to the General Assembly, is responsible for all
UNRWA activities as well as its administration.
UNRWA does not have an Executive Board, but it does have an Advisory
Commission, created in 1949 to advise and assist the Commissioner-Gen-
eral, with currently 29 members and four observers. The Advisory Com-
mission meets in June and November. Discussions of a more operational
nature are conducted by a sub-committee.
The Advisory Commission is an advisory body without executive authori-
ty. The nature of its proceedings is diplomatic and aims at sharing infor-
mation and providing advice to UNRWA, rather than adopting resolutions
or providing oversight. Instead of meeting within the politically significant
venues of the UN’s headquarters in New York or Geneva, the Advisory Com-
mission rotates its meetings within UNRWA’s host countries. 
UNRWA benefits from the fact that donors and host countries as key con-
stituencies are represented in the Advisory Commission. However, this can
also constitute a challenge, as political differences affect discussions of
organizational and operational matters. The Advisory Commission has fre-
quently been reluctant to consider sensitive neutrality-related issues. When
Advisory Commission members are unable to reach consensus, issues are
typically not tabled. Some Advisory Commission members have demanded
that UNRWA remove discriminatory sentences from textbooks used in its
schools, while other Advisory Commission members remain opposed to it.
Over the last year, the Advisory Commission did not agree to discuss the
neutrality challenges posed by UNRWA’s staff unions because of political
sensitivities.
These governance arrangements mean that UNRWA cannot rely on the
needed political support to effectively address neutrality issues, which, if
not provided by the General Assembly, should be provided by the Advisory
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Commission or any other governance arrangement. The international com-
munity needs to play its part in ensuring that UNRWA fulfils its mandate.
The Chair recommends to:
2.
Request the Advisory Commission to fulfil its role by effec-
tively advising and assisting UNRWA on fulfilling its man-
date, including by:
a. Convening at the UN in New York at Permanent
Representative level once a year.
b. Setting neutrality as a standing agenda item at its
twice-yearly meeting.
c. Creating an Advisory Commission Working Group on
neutrality and integrity issues, and inviting host coun-
tries and Israel to present their concerns.
3.
Explore additional governance arrangements to assist in
providing strategic direction to UNRWA and improving exter-
nal communications.
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IV. Management and
oversight mechanisms
Management and oversight play a key role in ensuring UNRWA reliably im-
plements its organizational policies, agreed procedures and practices on
neutrality. UNRWA has important management and oversight mechanisms
and procedures in place. However, there is a need to strengthen and restruc-
ture relevant departments and reinforce efforts on the nascent Enterprise
Risk Management System. Some changes to the modes of management of
international and local staff and frameworks for project monitoring are also
recommended to ensure UNRWA better manages its neutrality obligations.
Of note, some of these workstreams to strengthen UNRWA’s oversight and
accountability functions have already been initiated.
5
UNRWA currently implements and enforces neutrality based on the fol-
lowing pillars:
•
A regulatory framework and policies with key elements relating to
neutrality, such as International and Area Staff Regulations and
Rules; a Code of Ethics; Standards of Conduct; and specialized poli-
cies, such as a social media policy.
•
Operational responses, i.e. monitoring and responding to neutrality
concerns in UNRWA installations and education activities.
•
Outreach and training on neutrality for staff and other personnel.
•
Communication and outreach to external stakeholders on neutrality.
Procedures for complaints about alleged staff misconduct and unauthor-
ized use of the UNRWA name and logo.
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UNRWA has in place three specialized bodies leading or supporting these
workstreams:
•
UNRWA Neutrality Task Force: A senior-level group including the Com-
missioner-General, convened at short notice when critical neutrality
incidents occur or are alleged.
•
Humanitarian Principles Team: Led by the Senior Humanitarian Prin-
ciples Coordinator
6
under the Chief of Protection, this team ensures
that UNRWA’s operations and services are delivered in compliance
with the humanitarian principles, including neutrality. The team is in-
volved in policy development, data coordination, training and
outreach.
•
Humanitarian Principles Working Group: This standing body compris-
es department directors who engage with issues related to the hu-
manitarian principles across the agency.
Importantly, the Senior Humanitarian Principles Coordinator is currently
housed under the Protection Division, i.e. in UNRWA operations rather than
its management or oversight architecture. Neutrality activites are mostly
funded through voluntary contributions. Given neutrality’s organizational
significance to UNRWA, it is recommended that a central neutrality function
be established in UNRWA’s Executive Office. This would increase UNRWA’s
ability to effectively coordinate relevant internal entities such as the De-
partment of Legal Affairs, communications, partnerships, human resourc-
es and risk management functions.
Management
UNRWA has several organizational and management particularities with
an impact on neutrality. Firstly, the agency shows a high degree of vertical
integration, i.e. a direct delivery and implementation of the services it over-
sees, as opposed to outsourcing to implementing partners or suppliers.
Secondly, UNRWA covers a vast range of activities, from refugee protection
and curriculum development, to garbage collection in camps and commu-
nities. Thirdly, a small number of international civil servants (less than 1
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per cent of UNRWA’s total workforce) leads a vast majority of local area
staff, mainly due to scarce resources and UNRWA’s reliance on voluntary
contributions. UNRWA has not sufficiently modernized its management
structure, organization or internal communications to account for this or-
ganizational set-up, or to adapt to current management practices within or
outside the UN. In 2020, UNRWA launched a series of measures, referred to
as the ‘Management Initiatives,’ to reinvigorate and strengthen its manage-
ment system. However, several critical areas, such as oversight, have not
been sufficiently addressed, as will be further detailed below.
UNRWA’s enterprise risk management is another nascent area that war-
rants reinforced and accelerated efforts in view of the neutrality challeng-
es. Identifying neutrality as a central organizational risk and defining and
implementing continuous monitoring and holistic mitigation measures
could help more systematically control this risk. The tool could also help
allocate resources to neutrality-related efforts in a more rational and effi-
cient manner.
With regards to implementing change initiatives, there are challenges re-
lated to UNRWA’s staffing structure. UNRWA area staff often remain em-
ployed at UNRWA throughout their careers, which is attributable, at least
in Gaza, to mobility restrictions and the limited availability of other em-
ployment options. The fact that UNRWA is a major employer can create a
culture resistant to modernization and reform across levels and roles, as
such efforts could entail job cuts. This contextual factor makes change a
more complex endeavour for UNRWA management. However, the ability to
change and adjust must remain a high priority to ensure the organization
can work effectively and efficiently, including to ensure neutrality.
Internal oversight
The Department of Internal Oversight Services (DIOS) is UNRWA’s inter-
nal oversight body.
7
Its mandate is set out in Organizational Directive 14
(2020),
8
and it consists of three divisions for the oversight functions of
internal audit, evaluation and investigation. The Investigations Division is
responsible for investigating allegations of neutrality breaches. DIOS exer-
cises operational independence and has the authority to initiate, carry out
and report on any action it considers necessary.
9
An Advisory Committee
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on Internal Oversight (ACIO) provides expert advice to DIOS and the Com-
missioner-General.
The investigation mandate of DIOS is administrative in nature and covers
various forms of misconduct, such as fraud and corruption, sexual ex-
ploitation and abuse, abuse of authority, or failure to observe regulations,
rules and other administrative issuances, policies and procedures, includ-
ing neutrality breaches. Serious misconduct constitutes grounds for sum-
mary dismissal.
DIOS overall has sound mechanisms and procedures in place to address
alleged neutrality breaches. However, there are significant capacity con-
straints as well as indications that the structural set-up for reporting and
the intake of allegations entails security concerns for staff and personnel
that could also result in an underreporting of potential breaches, as further
detailed below.
UNRWA is a participating organization of the Joint Inspection Unit (JIU),
which provides independent oversight for efficiency, effectiveness and co-
ordination across the UN. The JIU has undertaken reviews of the investi-
gation function (2020)
10
and the internal pre-tribunal appeal mechanisms
(2023)
11
in the UN system. The JIU overall concludes that the responsibility
for UNRWA’s investigation activities is fragmented at the intake, preliminary
assessment and investigation stages. Of note, this led the ACIO to recom-
mend an evaluation of DIOS in the form of a commissioned, independent
assessment of the agency’s investigation function.
Reporting and intake of allegations
All UNRWA staff and personnel have an obligation to report misconduct and,
in turn, a right to be protected from retaliation for making such reports in
good faith and cooperating with investigations. Allegations of misconduct
can be reported in a variety of ways, including anonymously through the
DIOS investigation hotline, the Field Investigation Office and supervisors.
Between 2017 and 2022, the annual number of alleged neutrality breaches
was between 7 and 55, with an average of 21 alleged breaches per year.
Since October 2023, the number of alleged breaches has escalated sig-
nificantly. Serious allegations recently led the UN Secretary-General to
establish this Independent Review of Neutrality, in light of the extremely
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serious reputational, financial, political and security implications of such
allegations. Between January 2022 and February 2024, the Investigations
Division received 151 neutrality-breach allegations. Most alleged neutrality
breaches relate to social media posts, reported to UNRWA through external
sources. UNRWA has reviewed all external allegations of breaches of neu-
trality and opened investigations where it has found prima facie evidence
of misconduct, more than half of the allegations brought up.
The decentralized intake of allegations currently in place may result in in-
consistent reporting of potential breaches. This is a concern first noted
by the JIU report on UN internal investigations (2020), which flagged risks
due to the decentralized intake and pre-assessment of allegations within
UNRWA (and in nine other UN agencies). Allegations of misconduct cur-
rently have to be channelled through one of DIOS’s six intake committees,
established at headquarters and in the five field offices. Allegations, includ-
ing unauthorized public statements and related activities that could war-
rant further investigation, are brought to intake committees for their pre-as-
sessment first and to recommend the course of action.
In Gaza and its field offices, the volatile context and security challenges
may prevent reporting of allegations and investigating at the local level.
Neutrality allegations in the Gaza field offices are currently directly chan-
nelled to DIOS headquarters. Field office investigators in Gaza risk their
personal security. To remediate this, shortly before hostilities broke out in
October 2023, DIOS assigned an international investigator to Gaza. How-
ever, due to the security situation, the individual was evacuated and now
works remotely.
At the present time, only sexual exploitation and abuse cases are formally
required to be handled in a centralized manner across all field offices by the
DIOS Investigations Division.
Investigations
A report of an investigation is produced when the alleged facts, following
investigation, indicate that the subject’s conduct may constitute miscon-
duct, based on a preponderance of evidence. Subsequently, UNRWA Legal
and Management, in accordance with the relevant policy (including Per-
sonnel Directive 10 on Disciplinary Measures and Procedures), determine
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whether the facts constitute misconduct and whether the investigation’s
conclusions demonstrate “clear and convincing evidence” for a potential
sanction or dismissal. At the disciplinary stage, the subject is given a sum-
mary of the allegations against them and invited to reply, according to DIOS
Investigation Policy. The range of disciplinary sanctions applied include,
often in combination, loss of salary, suspension from duty and demotion,
or termination of employment.
As of April 2024, 50 neutrality cases are under investigation. There is a
clear capacity challenge in managing the number of neutrality allega-
tions through existing structures and staff. Resources are scarce, limiting
UNRWA’s ability to attract, hire, train and retain suitable, experienced and
qualified investigators. The JIU investigations report states: “UNRWA fac-
es persistent challenges in handling the continuously growing number of
complaints and new investigation cases, which lead to a growing number
of ongoing investigation cases each year, adding to the backlog.”
As of April 2024, there are only six international investigator posts in DIOS,
two of which are vacant, along with three limited-duration contract positions
based on project funding. Furthermore, there are 16 DIOS field investigator
posts (11 of which are permanent investigators) based across the five field
offices. Given that alleged neutrality breaches are priority concerns in DIOS,
financial means are being sought to strengthen investigative capacity by
establishing a specialized Neutrality Investigations Unit.
In terms of investigation tools, DIOS, due to funding challenges, does not
have access to adequate investigation software, such as that used for in-
ternal investigations in the UN Secretariat’s OIOS. The software available in
DIOS was described as in need of updating.
Disciplinary mechanism: the UNRWA
Dispute Tribunal
Local area staff and international staff are entitled to appeal administrative
decisions, such as disciplinary measures in response to neutrality viola-
tions, first internally, before the UNRWA Dispute Tribunal,
12
and then before
the UN Appeals Tribunal.
A review of relevant UNRWA Dispute Tribunal jurisprudence that was decid-
ed between 2018 and March 2024 in relation to neutrality cases indicates
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that most relate to social media posts. In several instances, applicants who
appealed decisions on disciplinary sanctions by UNRWA cited the lack of
Arabic-language instructions and training on staff neutrality obligations.
Several staff invoked their right to freedom of expression.
The recent JIU assessment report
13
on UN internal pre-tribunal-stage
appeal mechanisms (2023) noted that all UNRWA administration of jus-
tice-related functions, including the Legal Office for Staff Assistance, are
underresourced.
14
It furthermore urged UNRWA to improve outreach and
communication, translation services and inclusivity, as well as access to
internal justice.
UNRWA property, procurement and project oversight
Undue outside influence on decisions related to UNRWA projects and ac-
tivities poses a significant risk to UNRWA’s neutrality. Hence it is crucial
to ensure the integrity of these decisions and processes. In this regard,
UNRWA has a developed system in place for external procurement, for in-
spections of premises, for monitoring and reporting on project progress,
and for internal and external evaluations. However, there is room to further
bolster existing systems, especially on monitoring.
As discussed further in the chapter on neutrality of installations, UNRWA
regularly inspects its installations and reports on any violations of neutral-
ity. Procurement is the responsibility of the Central Support Services Divi-
sion, regulated by an elaborate procurement manual
15
that specifies pro-
curement authorities and vendor vetting processes. All contracts are made
public, as are UNRWA’s audit reports, with a system in place to investigate
reported irregularities.
16
Responsibility for monitoring is placed with the Planning Department uti-
lizing a results-based monitoring system and a common monitoring ma-
trix, with dashboards that measure progress towards or deviations from
UNRWA’s strategic objectives and plans. However, a number of donors not-
ed a need for strengthened project management and monitoring measures
in the given operational context. This could include third-party monitoring
for particularly sensitive projects, as used elsewhere in similarly fragile op-
erating environments.
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2858521_0016.png
UNRWA’s independent Evaluation Division is part of DIOS. Charged with
generating evidence of the outcomes of UNRWA interventions, including
on the efficiency and effectiveness of donor funding used, the Evaluation
Division organizes and assures regular UNRWA- or donor-requested inter-
nal or external evaluations. It follows a detailed evaluation manual and
annual evaluation plans. Evaluation plans and reports are published on
UNRWA’s website.
Neutrality is addressed in some of the recent evaluations, but so far there
are no stand-alone reports on the issue. The Evaluation Division has sug-
gested a potential future evaluation on neutrality.
The Chair recommends to:
4.
Strengthen internal oversight capacity, especially DIOS and
the Ethics Office, e.g. through the secondment of staff from
OIOS or UN agencies to DIOS and the Ethics Office.
Expand the reach and presence of DIOS and the Ethics Of-
fice in UNRWA fields of operations.
Facilitate interactions between DIOS and external audit
structures, such as the UN Secretariat’s OIOS. In case of
grave allegations, the Commissioner-General to request the
UN Secretary-General to refer the investigation to OIOS.
Implement periodic evaluations of DIOS, as per previous rec-
ommendation by ACIO. 
5.
6.
7.
8.
Pending an evaluation, create a centralized Neutrality In-
vestigations Unit with international staff, that reports di-
rectly to DIOS. 
9.
Roll out the updated Code of Ethics and associated training
to all staff.
10.
Strengthen compliance with the Outside and Political Ac-
tivities Policy.
11.
Address neutrality as a strategic risk in the existing Enter-
prise Risk Management system and assign the responsibili-
ty for UNRWA neutrality to the Deputy Commissioner-Gener-
al Operational Support.
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2858521_0017.png
Management
12.
Reinforce the internationalization of UNRWA’s senior mana-
gerial area staff positions.
13.
Require managers, from the most senior levels down to
senior area staff, to assume more accountability for staff
neutrality, e.g. by mandating regular engagements with their
teams on neutrality.
14.
Increase the number of women in senior managerial posi-
tions among area staff.
15.
Develop and implement tailored training programmes on
management and oversight for senior area staff who are
front-line managers and supervisors.
Projects
16.
Establish a framework with interested donors on project
management and monitoring to ensure transparency and
traceability of projects.
17.
Explore the possibility of third-party monitoring for sensi-
tive projects.
18.
Determine safeguards to ensure that projects are in line
with UNRWA’s overall objectives.
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V. Neutrality of staff
UNRWA employs more than 32,000 staff and personnel, 0.8 per cent of
whom are international and 99.2 per cent locally recruited. This includes
over more than 5,000 daily paid workers. All categories of UNRWA person-
nel – international and locally recruited – must deliver their functions in
compliance with the principle of neutrality.
Regulatory Framework
The UN Staff Rules lay out the general principles for appropriate conduct of
international civil servants:
They shall conduct themselves at all times in a manner befitting their status as
international civil servants and shall not engage in any activity that is incompatible
with the proper discharge of their duties with the United Nations. They shall avoid any
action and, in particular, any kind of public pronouncement that may adversely reflect
on their status, or on the integrity, independence and impartiality that are required by
that status.
17
These obligations apply to locally recruited staff, as stipulated in UNRWA
Area Staff Regulation (2018), article 1.4:
Staff members shall conduct themselves at all times in a manner befitting their status
as employees of the Agency. They shall not engage in any activity that is incompatible
with the proper discharge of their duties with the Agency. They shall avoid any action
and in particular any kind of public pronouncement which may adversely reflect on
their status, or on the integrity, independence and impartiality which are required by
that status. While they are not expected to give up their national sentiments or their
political and religious convictions, they shall at all times bear in mind the reserve and
tact incumbent upon them by reason of their employment with the Agency.
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The conduct and obligations of UNRWA staff and personnel regarding
neutrality are governed by a number of UN-wide documents, as well as
UNRWA-specific guiding documents, as laid out in UNRWA’s Neutrality
Framework: The UN Charter; Standards of Conduct for the International
Civil Service; UNRWA Area and International Staff Regulations; Area Staff
Rules and International Staff Rules; personnel directives; and administra-
tive issuances.
18
In addition to the core regulatory frameworks, UNRWA has developed an
extensive body of related standards and policies, notably a Code of Eth-
ics (updated 2024),
19
a policy on personal use of social media and guide-
lines (2021, updated 2024),
20
and staff standards of conduct.
21
These are
disseminated through staff information materials and training in Eng-
lish and Arabic.
The general principle reflected in the agency’s regulatory framework is that
its personnel must be neutral – and be seen to be neutral – at all times.
As UN personnel, they may maintain their personal convictions. Howev-
er, as humanitarian actors, their commitment to neutrality requires limits
and constraints to be exercised in ensuring that these personal convictions
do not interfere with their duties for the agency. Neutrality entails obliga-
tions that all personnel must follow, both on the job and during their free
time. Each member of staff and personnel bears primary responsibility for
“knowing, understanding and complying with the applicable parts of the
regulatory framework.”
22
Further, “all staff have an obligation to report mis-
conduct and are protected from retaliation for making such reports in good
faith and cooperating with investigations or audits.”
A number of policies and procedures are recent or recently updated and
are currently being implemented across UNRWA, from headquarters to op-
erations in the five fields of operations. However, these measures are being
carried out in the context of a financial crisis within UNRWA, where training
may be underfunded.
Before employment, all UNRWA staff and personnel make a self-declara-
tion regarding criminal offences, provide a confirmation by host authorities
of a clean criminal record, and are screened against the UN sanctions list.
Contracts signed by all UNRWA staff include copies of the following: Area
Staff Regulations and Rules; Code of Ethics; Impartiality and Neutrality of
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UNRWA staff; Prohibition of Violence; Revised Standards of Conduct; and
Mandatory Learning Courses.
Daily paid workers’ contracts specify that they “shall not engage in public
controversies of a political, racial, religious or ideological nature... and shall
opt for non-violent means of dealing with conflict.”
23
They are expected to
uphold these values at all times. Failure constitutes grounds for discipli-
nary measures, including summary dismissal for serious misconduct.
UNRWA’s approach to preventing neutrality breaches focuses on the obliga-
tion of individual staff members to know and respect the principle of neu-
trality, as reflected in elaborate contractual arrangements and the Code of
Ethics. However, the responsibility of senior management and area-based
managers to ensure their teams fully understand what is expected of them
on neutrality is neither articulated nor enforced.
UNRWA developed a Code of Ethics (updated on 24 February 2024) that
further details the principles and expected standards of conduct.
24
It ex-
emplifies misconduct as “Attending demonstrations or signing petitions
that are political or could become politicized,” which is considered a breach
of the principle of neutrality. Displaying controversial flags or symbols, or
holding political meetings or religious services in UNRWA installations are
also breaches of the principle of neutrality.
25
Any involvement in a milita-
rized group that promotes discrimination or violence, such as Hamas or
Islamic Jihad, violates the principle of neutrality.
The Ethics Office advises staff and management on the standards of con-
duct expected from international civil servants across an organization of
more than 32,000 staff and personnel. The Review Group notes that the
Code of Ethics and Ethics Office are useful mechanisms for setting bound-
aries for staff conduct in terms of neutrality. However, it is noted, that
the Ethics Office consists of only three staff members and needs to be
strengthened urgently.
Screening and vetting
UNRWA has a vetting system in place to screen staff and personnel before
and during employment.
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Prior to employment:  
•
Standard vetting questions are in place on the recruitment platform,
requiring all applicants to self-declare and provide details, if applica-
ble, related to criminal offences, violations of international human
rights or international humanitarian law, disciplinary measures or ad-
ministrative measures, or workplace disciplinary processes or inves-
tigations.  
•
UNRWA screens the names of all potential recruits, irrespective of
their contract type, against Clear-Check, a UN system database that
includes the UN sanctions list.
26
•
UNRWA conducts checks with local authorities. Area staff are
screened against criminal records through requests for non-convic-
tion letters from the local authorities, confirming a clean criminal re-
cord or host Government security clearance.  
During and after employment:  
•
In Gaza and the West Bank, all staff payments are processed through
the Bank of Palestine, which vets against the EU sanctions list and is
subject to the banking regulatory framework governed by the Pales-
tinian Monetary Authority.  
•
UNRWA screens all active and recently separated personnel who re-
ceive monetary compensation from UNRWA against the UN sanc-
tions list in a biannual screening exercise. To improve the screening
process, UNRWA introduced the digital LexisNexis Risk Solutions sys-
tem in 2023 to facilitate the correct matching of names against lists.
Of note, UNRWA screens names using the New Consolidated List
27
es-
tablished and maintained by the Security Council Committee. However, to
date, Hamas and Islamic Jihad, for example, have not been included in this
list by the UN Security Council.
UNRWA shares staff lists (names and functions) annually with host coun-
tries (Lebanon, Jordan and Syria), and with Israel and the US for East Je-
rusalem, Gaza and the West Bank.
28
Sharing information on UN staff with
host countries is a regular practice that follows the Convention on Immunity
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and Privileges. It is then the responsibility of these States to alert UNRWA
of any information that may deem a staff member unworthy of diplomatic
immunity. Of note, the Israeli Government has not informed UNRWA of any
concerns relating to any UNRWA staff based on these staff lists since 2011.
During meetings with Israeli officials, it was communicated that Israel does
not consider the sharing of the staff list as a screening or vetting process,
but as a standard procedure for the registration of UN and diplomatic staff
to ensure their privileges and immunities.
The Israeli Ministry of Foreign Affairs informed that until March 2024, they
had received staff lists without identification (ID) numbers. On the basis of
the March 2024 list, which contained staff ID numbers, Israel made public
claims that a significant number of UNRWA employees are members of
terrorist organizations. However, Israel has yet to provide supporting evi-
dence of this.
All UNRWA beneficiaries, contractors, vendors, non-State donors, or any
other individual or organization affiliated with UNRWA are screened annu-
ally by the agency using the UN and the World Bank sanctions lists. This ex-
ercise concerns approximately 8 million records.
29
No matches have been
documented to date. UNRWA also receives recommendations from the au-
dit division of the screening process against the UN sanctions list.
30
Despite a comprehensive set of measures to screen and vet staff and other
individuals or organizations affiliated with UNRWA, these measures do not
allow sufficient verifications. The UN sanctions lists are limited to a small
number of individuals, and UNRWA lacks the support of intelligence servic-
es to undertake efficient and comprehensive vetting.
Training
UNRWA established a dedicated Humanitarian Principles Team, which sup-
ports the agency in respect of neutrality. As of 2024, the team runs the fol-
lowing training programmes:
•
All-staff mandatory neutrality and social media e-learning course.
•
In-person training on the humanitarian principles, primarily aimed at
area-level staff and educational personnel.
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2858521_0023.png
•
In-person training on integrated assessments for protection
team members.
•
In-person training on the humanitarian principles and integrated as-
sessments for installation managers and their deputies.
A new and improved e-learning course on the humanitarian principles, in-
cluding neutrality, is being rolled out agency-wide.
The mandatory online training programme needs to be complemented
with more in-person trainings. It is also advisable to foster a more system-
atic engagement between UNRWA managers and personnel about how
to apply the humanitarian principles, particularly neutrality, in practice in
their daily work.
Staff care
Neutrality breaches by UNRWA personnel often take the form of social me-
dia posts, particularly following incidents of violence affecting colleagues
or relatives. One preventive action could be to ensure that personnel are
given a space to discuss these traumatic incidents.
Protection and neutrality officers are a vital resource for staff, but there
are only a few, with one Staff Care Officer for all of UNRWA’s West Bank
operations. Staff and mental health care issues should be a higher priority
but are constrained by a lack of resources. UNRWA’s recent appointment of
the Head of Staff Care is a welcome development, but additional dedicated
resources for staff care are needed.
The Chair recommends to:
19.
Update the Neutrality Framework, especially to address the
challenges posed by social media and new technologies.
20.
Ensure awareness of the framework and compliance
through on-site training programmes in all field sites for staff
and personnel.
21.
Announce Standard Operating Procedures (SOPs) on how
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2858521_0024.png
to deal with potential future allegations of irregularities, mis-
conduct or neutrality breaches by staff.
22.
Identify and implement additional ways to screen UNRWA
staff at an early stage of the recruitment process.
23.
Implement regular sharing of digital staff lists with host
countries and Israel, with all required information, including
ID numbers and functional titles, to undertake additional
screening. In response, host countries and Israel to provide
UNRWA with screening results and evidence of any red flags.
24.
Establish a continuous vetting process, especially in the
event of staff promotion.
25.
Strengthen UNRWA’s capacities to detect public expressions
of staff views on social media that are not in accordance
with staff regulations.
26.
Improve reporting when breaches occur, including by
strengthening existing whistleblower protection.
27.
Strengthen the disciplinary processes across the agency.
28.
Establish the international position of Staff Care Specialist –
one in each of UNRWA’s five fields of operations.
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VI. Neutrality of installations
UNRWA has approximately 1,000 installations across its five fields of oper-
ations, which include schools, health centres, warehouses, and area, field
and headquarters (HQ) offices.
31
In line with UNRWA’s Neutrality Framework, the agency is responsible for
ensuring the neutrality of these installations, including preventing misuse
for political or military objectives. In return, it is important to note that by
virtue of the UN Charter and the Convention on Privileges and Immunities,
which grant inviolability of UN premises and personnel, host States or de
facto authorities are obliged to respect the inviolability of these installa-
tions, and to afford UN premises active protection from any outside threat
or disturbance. UN premises may not be entered unauthorized, and the UN
must be permitted to control activities occurring on those premises unless
it requests local authorities to intervene.
UNRWA has due diligence mechanisms in place to prevent neutrality
breaches in its installations, and it has established protocols to respond to
breaches. However, security and capacity challenges may hamper their due
implementation.
UNRWA delivers on its obligations in two ways, which will be further dis-
cussed below. Firstly, it regularly inspects and assesses the compliance
of premises with the principle of neutrality. Secondly, it signals any critical
breaches and reports on them to host States and donors.
Regular inspections
In line with UNRWA’s SOPs, each installation is to be inspected quarterly un-
der the responsibility of the UNRWA Protection Division.
32
UNRWA organiz-
es “integrated assessments” by a team that includes installation managers,
protection team leaders, humanitarian principles focal points and others,
supported by the relevant field management and HQ structures.
33
Actual as-
sessments may not always occur on schedule, and teams often comprise
only two staff members carrying out the inspection following specified pro-
cedures.
34
Depending on security or staffing levels, senior area officers may
also be required to conduct the integrated assessments. HQ departments,
including the Executive Office, are informed quarterly about the status of
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integrated assessments and efforts to follow up on identified issues.
35
The
most frequent issues identified during assessments are a lack of UN sign-
boards, of no-weapons signboards and of UN flags.
36
The SOPs for regular inspections appear to be appropriate. International
staff should conduct integrated assessments whenever possible. However,
quarterly inspections are insufficient to ensure the neutrality of the premises.
The responsible installation managers, as well as school principals and dep-
uty principals, may require support to carry out this function more regularly.
In addition, the daily monitoring of installations needs to be more robust.
Critical breaches
Critical breaches to the neutrality of UNRWA’s installations and the inviola-
bility of its premises could include the discovery of weapons, military ac-
tivity, or cavities and tunnel openings, but also of Israeli military incursions.
In such events, UNRWA protests against these breaches and immediately
reports them to host countries, donors and other relevant actors.
A limiting factor to the potential discovery of critical breaches is the fact
that UNRWA, as a UN agency, does not have policing, military or wid-
er investigative capacities or competencies required to detect such
breaches. As a starting point, closer dialogue between UNRWA, the
Israeli Defence Forces and the Palestinian Authority should remedy
some of the information gaps and attend to the shared responsibilities.
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The Chair recommends to:
29.
Train staff on the civilian nature of UNRWA’s facilities.
30.
Organize  community-awareness campaigns  on the civilian
nature of UNRWA’s facilities.
31.
Ensure additional capacities to  increase the frequency
and widen the scope of installation visits to also include mil-
itary misuse of UNRWA facilities.
32.
Strengthen the communication and collaboration with host
countries and Israel on the misuse of UNRWA’s facilities, in-
cluding the option of UNRWA being able to request joint visits.
33.
Establish transparent reporting to donors on the misuse of
UNRWA’s facilities.
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VII. Education
UNRWA’s education system is crucial to several hundreds of thousands of
Palestinian children. UNRWA provides elementary and preparatory educa-
tion for half a million pupils in 706 schools, with 20,000 educational staff.
Gaza’s education system, which represents 40 per cent of UNRWA’s educa-
tional staff, has collapsed due to the ongoing conflict, with all children in
Gaza now out of school.
UNRWA’s practice is to use host-country curriculums and textbooks in ac-
cordance with UNESCO recommendations.
37
This enables Palestine ref-
ugee students to transition from UNRWA to host-country schools.
38
The
textbooks are not produced by UNRWA but the agency’s neutrality obliga-
tions apply, as the textbooks are being used in UNRWA or UNRWA-fund-
ed schools. In addition to textbooks, locally produced educational supple-
ments are sometimes used in UNRWA schools.
UNRWA has received sustained criticisms, mainly from Israel and NGOs
39
over the alleged presence of hate speech, incitement to violence and anti-
semitism in Palestinian Authority textbooks and educational supplements.
The European Parliament has recently adopted a resolution reflecting this
issue. Some donors have also raised significant concerns.
40
Upon review of three major international assessments and academic stud-
ies on the issue of Palestinian Authority textbooks, two identified bias and
non-compliant content but did not provide evidence of antisemitic refer-
ence.
41
A third, the Eckert report, identified two examples that displayed
antisemitic content but noted that one had already been removed; the other
has been significantly altered.
42
It remains unclear whether the alteration
has in fact removed the antisemitic content from the remaining example.
UNRWA has consistently worked on ensuring neutrality in its education. To
that end, it has developed and implemented a range of frameworks, man-
uals, mechanisms and procedures to align all educational materials and
methods with UN values, principles and guidelines, including:
•
The Framework for Quality Analysis and Implementation of Curriculum.
43
•
A programme and policy to integrate human rights, conflict resolution
and tolerance in schools.
44
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•
The Neutrality Review Manual,
45
a guiding tool for reviews of learn-
ing materials and host-country curriculum content. It centres on UN
principles including three assessment areas: UN Position, Educa-
tional Appropriateness, and Adherence to UNESCO Standards.
•
A task force
46
to review Palestinian Authority textbooks, undertaking
rapid reviews
47
to ensure alignment with UN values in textbooks and
teachers’ manuals.
•
The Critical Thinking Approach.
48
A manualized teaching approach
with explanations and questions for classroom use facilitating dis-
cussions and educating students to critically engage with available
knowledge.
49
This includes teacher training and on-site support.
50
•
Digital learning platforms for self-learning materials to support dis-
tance learning, which is the only authorized source of supplemental
material for teachers.
51
The most recent UNRWA Rapid Review of textbooks from the Palestinian
Authority is the 2022/2023 review. It found that 3.85 per cent of all textbook
pages contain “issues of concern to UN values, guidance, or position on the
conflict,” either because they are deemed “educationally inappropriate” or
because they are not in line with UNESCO standards.
52
Even if marginal, these issues constitute a grave violation of neutrality.
Among the various issues, recurrent ones were the use of historical maps
in a non-historical context, e.g. without labelling Israel; naming Jerusalem
as the capital of Palestine; naming cities in Israel as Palestinian cities; the
use of the word Zionist (e.g. “Zionist occupation” referring to Israel).
Of the 30 allegations made by NGOs of neutrality breaches in education-
al material, eight are linked to educational material from the Palestinian
Authority that is not used in UNRWA schools in Gaza.  The remaining 22
allegations related to Palestinian Authority textbooks used by UNRWA are
addressed in the classroom using the Critical Thinking Approach.
In addition to the procedures, frameworks and mechanisms in place,
UNRWA has worked with UNESCO since 2011 to reform curricula and
teaching materials, including in dialogue with national authorities.
After its previous reviews and dialogue with donors, UNRWA and UNESCO,
the Palestinian Authority has worked to alter the educational content that
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2858521_0030.png
does not meet UN values and standards. Nevertheless, the issue persists.
The Chair’s assessment is that UNRWA has been responsive to allegations
of neutrality breaches and criticism about the textbooks and initiated a range
of initiatives to ensure neutrality of its teaching material and the teaching. It
has developed a range of preventive and mitigatory mechanisms and pro-
cedures, including the Critical Thinking Approach.
53
The Digital Learning
Platform provides potential to streamline education across the five fields
of operation. The platform increases the amount of UNRWA-approved edu-
cational content and material, some of which comes from authorized third
parties, peer-to-peer support and professional dialogue. UNRWA could fur-
ther develop the digital platform. The platform can also facilitate the roll-
out of the 2022 UNRWA Media and Information Strategy,
54
which can better
equip teachers to guide students to critically address misinformation or
disinformation and promote information integrity.
55
Digital and social me-
dia are, on a global scale, major sources and channels of messaging that
goes against UN principles.
56
Despite these achievements, the presence of even a small fraction of prob-
lematic content in textbooks, supplemental material and teaching con-
tent remains a serious issue. More work needs to be undertaken between
UNRWA and the Palestinian Authority to pursue the replacement of prob-
lematic content, and to avoid the promotion of discrimination and incite-
ment to hatred and violence, and the spreading of antisemitic views that
contradict UN values and UNESCO standards.
The Chair recommends to:
34.
Review the content of all textbooks and supplements with
host countries, Israel and the Palestinian Authority.
35.
Ban any hate speech, incitation to violence and/or antise-
mitic references from host-country textbooks and locally
produced supplements in UNRWA schools. In the meantime,
stop using such material.
36.
Establish a yearly review of all textbooks and supplements
used in UNRWA schools together with UNESCO, and ensure
adherence to the 2023 UNESCO-adopted Recommendations
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2858521_0031.png
on Education for Peace, Human Rights and Sustaina-
ble Development.
37.
Empower more women area staff to take managerial respon-
sibilities within the UNRWA education system.
38.
Establish a dedicated channel, e.g. a hotline, for UNRWA to
receive alerts on problematic teaching content and to sup-
port teachers seeking advice. 
39.
Establish randomized teaching inspections in classrooms.
40.
Continue the digitalization of educational content and
pursue the use of digital teaching platforms to increase
transparency.
41.
Establish training for UNRWA Principals and teachers
on neutrality and other humanitarian principles, and on
human rights.
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VIII. Staff unions
UNRWA staff unions have a significant role in the relations between UNRWA
management and staff and the wider functioning of the agency. However, there
are long-standing concerns over politicization and interlinkages with Palestini-
an political factions, with a direct impact on UNRWA’s neutrality. Each of the five
field offices and the headquarters in Amman and Gaza have their own distinc-
tive union structure and related challenges, deeply engrained in the context in
which they operate.
There are frequent tensions between UNRWA management and staff unions at
all levels. In the past decades, UNRWA has experienced regular disputes regard-
ing issues such as salaries, agency reform, and insubordination and disciplinary
sanctions. These disputes frequently resulted in strikes and protests. Intimida-
tion tactics and threats forced numerous UNRWA directors to be transferred to
different positions and contexts for their own security.
In addition, there are a number of areas of concern regarding staff unions relat-
ing to neutrality:
•
Staff unions have sometimes resisted management disciplinary actions,
including on neutrality.
•
Staff unions’ elections are notably politicized. Local and national
competing political forces can be seen to use staff unions to pressure
the UNRWA leadership and influence decisions on service delivery or
project implementation to gain influence or support from the population.
•
UNRWA staff unions may have an undue influence on UNRWA’s
activities due to their role in salary negotiations. A periodical salary
survey is conducted to ensure that UNRWA area staff salaries do not fall
below local government pay rates. Historically, after the survey results
are issued and pay-scale adjustments are made by the Commissioner-
General, unions would strike for higher adjustments with backpay for the
time while striking. In 2023, union actions in the West Bank lasted nearly
100 days and were ultimately met with management implementing
the ‘No Work, No Pay’ principle for backpay. This further strained staff
relations and prompts timely discussions about how pay scales should
be decided, when and by whom.
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•
There is a long-standing concern about representativity given the lack of
quotas for gender or professional representation in union leadership.
UN staff representative bodies
57
(‘unions’) are typically mandated to advo-
cate for the rights, interests and welfare of UN personnel. As such, UN staff
unions should be representative of the workforce and are required to uphold
UN principles and values. Staff representatives have the same rights, duties,
obligations and privileges as other staff members;
58
they are independent
and should not receive any external influence or instruction.
To address the wide range of neutrality and general management challeng-
es, an urgent modernization of the union statute and operational structures
is needed. UNRWA’s Statute of the Area Staff Union was issued and agreed
upon in 1990, but it has not been updated since, despite many attempts.
The Chair recommends to:
42.
Reform the 6 November 1990 Statute of the Union of Area
Staff of UNRWA to align it with UN system Staff Union Stat-
utes and Regulations, especially as it relates to election of
staff union representatives.
43.
Ensure the workforce representativity of staff unions, includ-
ing by increasing women representation. Women comprise
half of UNRWA staff, but currently almost all staff union rep-
resentatives are men.
44.
Request, via an independent entity, dedicated neutrality vet-
ting for every staff union representative, beginning with the
most senior.
45.
Establish vetting procedures when staff union representa-
tives are elected.
46.
Outsource all issues related to the setting of pay and pay-re-
lated benefits to an independent entity comparable to the In-
ternational Civil Service Commission.
47.
Explore additional options for staff representation.
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IX. Strengthened partnership
with UN agencies
UNRWA has a long history of partnerships. The founding UNGA resolution
302 (1949) already calls for cooperation with other agencies and organiza-
tions. The World Health Organization has embedded experts in UNRWA HQ
for decades.
59
In addition, UNRWA is engaged in a plethora of cross-agency
partnerships, a concept that the UNGA fully supports, as expressed at the
tri-annual extensions of the mandate.
60
 UNRWA also has many field-based
partnerships with UN agencies, NGOs and community-based organiza-
tions. In the context of the current hostilities in Gaza, ad hoc and temporary
partnerships have been developed, such as agreements with IOM (shelter),
WFP (food distribution) and UNICEF (vaccinations). Meanwhile, UNRWA
retains its central and irreplaceable role of providing a platform – and in
many cases infrastructure – for these specialized activities.
UNRWA’s current financial and operational constraints resulted in its oper-
ations in Gaza being severely curtailed, unable to provide sufficient human-
itarian assistance to people in need. One option is for UNRWA to partner
more with other UN agencies and organizations on an ad hoc and tempo-
rary basis, and in full respect of UNRWA’s mandate. However, partnerships
are a sensitive issue for UNRWA. Some stakeholders view any substantive
involvement of other organizations in UNRWA’s activities as an attempt to
weaken UNRWA’s mandate. As such, the Commissioner-General’s partner-
ship initiative in 2022 was abandoned due to push-back from host Govern-
ments and staff associations who perceived partnerships as the beginning
of the dismantling of UNRWA. 
With some funding now diverted from UNRWA to other humanitarian or-
ganizations, especially for Gaza, while not modifying the agency’s mandate,
there is an imperative to work with these partners to ensure that immediate
humanitarian needs in Gaza are met. The Inter-Agency Standing Commit-
tee (IASC) Emergency Directors Group (EDG), comprising representatives
from about 20 IASC member organizations, should be asked to develop a
collective operational coordination plan for Gaza.
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There is also a potential for new alliances to increase UNRWA’s access
to additional funding. Partnerships would also be advantageous for other
agencies, who would benefit from UNRWA’s regional knowledge and ac-
cess while they themselves bring thematic expertise and external staffing
support to counter neutrality challenges.
The Chair recommends:
48.
The IASC EDG to develop recommendations on how other
local and international humanitarian organizations can sus-
tain and scale up support to UNRWA’s humanitarian opera-
tions in Gaza.
49.
UNRWA to enhance its participation in the humanitarian
coordination system by ensuring staff in number and skills
are dedicated to engaging in coordination architecture at
the cluster level.
50.
UNRWA to drive an internal cultural shift that redefines its
relationship to the rest of the humanitarian community and
its role within the coordination architecture, particularly
within the clusters.
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X. Conclusions and
recommendations 
Since 2017 UNRWA has established and updated a significant number of
policies, mechanisms and procedures to (a) ensure compliance with the
obligation to uphold the principle of neutrality, including the provision of
information and training for UNRWA staff to prevent breaches; (b) ensure
rapid and adequate responses to allegations or indications of breaches,
including reporting and investigation systems and routines; and (c) deter-
mine and implement disciplinary sanctions on personnel found to breach
the neutrality principles. 
However, important areas for further strengthening were identified. Be-
low are the main recommendations of this final report. The Chair is con-
fident that implementing these recommendations will help UNRWA ful-
fil its mandate.
Engagement with donors
The trust deficit between UNRWA and its donors has widened due to the
serious allegations against its staff. Even in the absence of allegations,
better communication with donors is required. Enhancing transparency
and consultation with donors is imperative to rebuild trust and strength-
en partnership.
1.
Increase the
frequency and strengthen the transparency
of
UNRWA’s
communication with donors
on its financial situa-
tion and on neutrality allegations and breaches:
a. Plan
regular updates
by UNRWA on its budget and the
structure of this budget, including in the Commission-
er-General’s direct interactions with Governments.
b.
Establish ‘Integrity Briefings’ for donors
interested in
supporting UNRWA on integrity and related issues, with
meetings or briefings held at UN headquarters in New
York or Geneva.
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Governance
UNRWA does not have an Executive Board, and the Advisory Commission
only advises the organization. UNRWA would benefit from stronger gov-
ernance structures in support of its senior leadership’s efforts. The inter-
national community should also support UNRWA in addressing neutrality
issues through these governance structures.
2.
Request the Advisory Commission to fulfil
its role by effec-
tively advising and assisting UNRWA on fulfilling its mandate,
including by:
a.
Convening at the UN in New York at Permanent Repre-
sentative
level once a year.
b.
Setting neutrality as a standing agenda item
at its
twice-yearly meeting.
c. Creating an
Advisory Commission Working Group on
neutrality and integrity issues,
and inviting host countries
and Israel to present their concerns.
3.
Explore
additional governance arrangements
to assist in pro-
viding strategic direction to the organization and improving
external communication.
Management and internal oversight
UNRWA’s management and internal oversight reform efforts are commend-
able and should be further expanded. Progress has been made, especially
in strengthening UNRWA’s DIOS and the Ethics Office, but further enhance-
ments are necessary.Commitments made by UNRWA senior management
to a number of donors, including in the Action Plan on UNRWA initiatives
shared in March 2024, have to be duly implemented.
4.
Strengthen internal oversight capacity,
especially DIOS and
the Ethics Office, e.g. through the
secondment of staff from
OIOS
or UN agencies to DIOS and the Ethics Office.
Expand the reach and presence
of DIOS and the Ethics Office
in UNRWA fields of operations.
37
5.
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6.
Facilitate
interactions between DIOS and external audit struc-
tures,
such as the UN Secretariat’s OIOS. In case of grave
allegations, the Commissioner-General to request the UN
Secretary-General to
refer the investigation to OIOS.
Implement
periodic evaluations of DIOS,
as per previous rec-
ommendation by ACIO.
Pending an evaluation, create a
centralized Neutrality Inves-
tigations Unit
with international staff, that reports directly to
the DIOS to oversee field office-led investigations. 
Roll out the updated
Code of Ethics
and associated in-person
training to all staff.
7.
8.
9.
10.
Strengthen compliance with the
Outside and Political Ac-
tivities Policy.
11.
Address neutrality as a
strategic risk in the existing Enterprise
Risk Management system,
and assign responsibility for
UNRWA neutrality to the Deputy Commissioner-General
Operational Support.
Management
12.
Reinforce the
internationalization
of UNRWA’s senior mana-
gerial area staff positions.
13.
Require managers, from the most senior levels down to sen-
ior area staff, to assume more accountability
for staff neutral-
ity,
e.g. by mandating regular engagements with their teams
on neutrality.
14.
Increase the number of
women in senior managerial positions
among area staff.
15.
Develop and implement tailored
training programmes on
management
and oversight for senior area staff who are
front-line managers and supervisors.
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Projects
Political influence on decisions related to UNRWA projects poses a signifi-
cant risk. Ensuring the neutrality of these decisions and processes is crucial.
16.
Establish a framework with interested donors on project
management and
monitoring to ensure transparency and
traceability of projects.
17.
Explore the possibility of
third-party monitoring
for sensi-
tive projects.
18.
Determine safeguards to ensure that
projects are in line with
UNRWA’s overall objectives.
Neutrality of staff
UNRWA faces challenges due to increased politicization among its staff,
affecting its neutrality. Strategies for prevention, monitoring of compliance
in accordance with international and area staff rules and regulations and
relevant standards of conduct, as well as an appropriate response to poten-
tial breaches are crucial.
19.
Update the Neutrality Framework,
especially to address the
challenges posed by social media and new technologies.
20.
Ensure awareness of the framework and compliance
through on-site
training programmes
in all field sites for staff
and personnel.
21.
Announce Standard Operating Procedures (SOPs) on
how to
deal with potential future allegations
of irregularities, miscon-
duct or neutrality breaches by staff.
22.
Identify and implement
additional ways to screen
UNRWA
staff at an early stage of the recruitment process.
23.
Implement regular
sharing of digital staff lists
with host
countries and Israel, with all required information, including
ID numbers and functional titles, to undertake additional
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screening. In response,
host countries and Israel to provide
UNRWA with screening results
and evidence of any red flags.
24.
Establish a
continuous vetting process,
especially in the event
of staff promotion.
25.
Strengthen UNRWA’s capacity to
detect public expressions of
staff views on social media
that are not in accordance with
staff regulations.
26.
Improve
reporting
when breaches occur, including by
strengthening existing
whistleblower protection.
27.
Strengthen the
disciplinary processes
across the agency.
28.
Establish the international position of
Staff Care Specialist
–
one in each of the five fields of operations.
Neutrality of installations
UNRWA’s facilities have sometimes been misused for political or military
gains, undermining its neutrality. If the prevention of and response to the po-
litical misuse of UNRWA installations have been efficient, the agency has had
more difficulty appropriately addressing the use of its installations for mili-
tary purposes. Preventive measures, enhanced monitoring and transparent
reporting are necessary to address this issue effectively.
29.
Train staff
on the civilian nature of UNRWA’s facilities.
30.
Organize
community-awareness campaigns
on the civilian
nature of UNRWA’s facilities.
31.
Ensure additional capacities to
increase the frequency and
widen the scope of installation visits
to also include military
misuse of UNRWA facilities.
32.
Strengthen the
communication and collaboration with
host countries and Israel
on the misuse of UNRWA’s facili-
ties, including the option of UNRWA being able to request
joint visits.
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33.
Establish transparent
reporting to donors
on the misuse of
UNRWA’s facilities.
Neutrality of education
UNRWA’s education system is crucial to several hundreds of thousands
of Palestinian children. However, it has been reported for many years that
schools may have been utilized to spread political views, including antisemit-
ic content, violating neutrality principles as well as not respecting UNESCO
standards and UN values.
UNRWA has made significant progress in the past few years to mitigate the
risks attached to the promotion of hate and the incitation of violence in text-
books and in the classroom. UNRWA has implemented measures to confront
this issue, including by instituting a Critical Thinking Approach and digitaliz-
ing its curriculum.
Any textbooks spreading antisemitic views, promoting discrimination and
incitement to hatred and violence contradict UN values and UNESCO stand-
ards. Even if marginal, this constitutes a grave violation of neutrality. In Gaza
and the West Bank such textbooks are those of the Palestinian Authority, but
this does not relieve UNRWA of its responsibilities when these textbooks are
used in UNRWA or UNRWA-funded schools. UNRWA needs to implement a
zero-tolerance policy on this issue.
34.
Review the content of all textbooks and supplements
with
host countries, Israel and the Palestinian Authority.
35.
Ban any hate speech, incitation to violence
and/or
antisemitic
references
from host-country textbooks and locally produced
supplements in UNRWA schools. In the meantime, stop using
such material.
36.
Establish a
yearly review of all textbooks and supplements
used in UNRWA schools together with UNESCO, and ensure
adherence to the 2023 UNESCO-adopted Recommenda-
tions on Education for Peace, Human Rights and Sustaina-
ble Development.
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37.
Empower
more women area staff to take managerial
responsi-
bilities within the UNRWA education system.
38.
Establish a
dedicated channel,
e.g. a hotline, for UNRWA to
receive alerts
on problematic teaching content and to support
teachers seeking advice. 
39.
Establish
randomized teaching inspections
in classrooms.
40.
Continue the
digitalization of educational content
and pursue
the use of digital teaching platforms to increase transparency.
41.
Establish
training for UNRWA Principals and teachers
on neu-
trality and other humanitarian principles, and on human rights.
Staff unions
Over the years, political factions have used UNRWA’s staff unions to pressure
the agency’s leadership and influence decisions on service delivery or project
implementation. This is not the role of staff unions. The politicization of staff
unions is considered one of the most sensitive neutrality issues and needs to
be addressed with the full support of the Advisory Commission. 
42.
Reform the 6 November 1990 Statute of the Union of Area
Staff
of UNRWA to align it with UN system Staff Union Stat-
utes and Regulations, especially as it relates to the election
of staff union representatives.
43.
Ensure the
workforce representativity of staff unions,
includ-
ing by increasing women representation.
Women comprise half of UNRWA staff, but currently almost
all staff union representatives are men.
44.
Request, via an independent entity,
dedicated neutrality vet-
ting
for every staff union representative, beginning with the
most senior.
45.
Establish
vetting procedures
when staff union representa-
tives are elected.
42
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46.
Outsource all issues related to the
setting of pay and pay-re-
lated benefits
to an independent entity comparable to the
International Civil Service Commission.
47.
Explore additional options for
staff representation.
Enhanced cooperation with UN agencies
Considering the ongoing crisis in Gaza, and in full respect of UNRWA’s
mandate, some temporary measures could be considered to help UNRWA
ensure the delivery of life-saving assistance to Palestinians at this critical
time, such as:
48.
The
IASC EDG to develop recommendations
on how other
local and international humanitarian organizations can sus-
tain and scale up support to UNRWA’s humanitarian opera-
tions in Gaza.
49.
UNRWA to enhance its participation in the humanitarian co-
ordination
system by ensuring staff in number and skills are
dedicated to engaging in coordination architecture at the
cluster level.
50.
UNRWA to drive an internal
cultural shift
that redefines its
relationship to the rest of the humanitarian community
and its
role within the coordination architecture, particularly within
the clusters.
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XI. Endnotes
1 “Terms of Reference, Group to Conduct an Independent Review of
mechanisms and procedures to ensure adherence by UNRWA to the
humanitarian principle of neutrality” (Annex A)
2 United Nations General Assembly, “Strengthening the Coordina-
tion of Humanitarian Emergency Assistance of the United Nations,
resolution 46/182.” Available at: https://digitallibrary.un.org/re-
cord/135197?v=pdf (accessed 12 April 2024).
3 Executive Office Instruction No. 1, UNRWA Neutrality Framework
(2017), p. 1. (internal document)
4 Ibid.
5 UNRWA communication to donors, “Strengthening UNRWA’s Over-
sight and Accountability Functions,” February 2024.
6 In late 2021, UNRWA turned the Neutrality Coordinator position into a
Senior Humanitarian Principles Coordinator position to anchor UNRWA
projects and services within the broader obligations of the humanitari-
an principles (humanity, impartiality, independence, neutrality).
7 See DIOS website, available at dios.unrwa.org.
8 UNRWA, Organization Directive No. 14: Charter of the Department of
Internal Oversight Services (1 October 2020). Available at: dios.unrwa.
org/sites/default/files/revised_od14_dios_charter_1_october_2020.
pdf (accessed 16 March 2024).
9 Ibid.
10 Review of the state of the investigation function: progress made
in the United Nations system organizations in strengthening the inves-
tigation function: report of the Joint Inspection Unit (United Nations
publication, 2020). Available at: www.unjiu.org/sites/www.unjiu.org/
files/jiu_rep_2020_1_english_0.pdf (accessed 29 February 2024).
11 Review of the internal pre-tribunal-stage appeal mechanisms avail-
able to staff of the United Nations system organizations: report of the
Joint Inspection Unit (United Nations publication, 2020). Available at:
www.unjiu.org/sites/www.unjiu.org/files/jiu_rep_2023_2_english_0.
pdf (accessed 29 February 2024).
12 “UNRWA dispute tribunal.” Available at: www.unrwa.org/unrwa-dis-
pute-tribunal (accessed 16 March 2024).
Review of the internal pre-tribunal-stage appeal mechanisms (United
Nations publication, 2020).
13 UNRWA, “Joint Evaluation and Audit of the UNRWA Gender Equality
Strategy 2016-2022.” Available at: https://www.unrwa.org/resources/
dios-and-evaluation/joint-evaluation-and-audit-unrwa-gender-equali-
ty-strategy-2016-2022 (accessed 11 April 2024).
14 United Nations, “Review of the internal pre-tribunal-stage appeal
mechanisms available to staff of the United Nations system organiza-
tions, Report of the Joint Inspection Unit” (2023). Available at: https://
www.unjiu.org/sites/www.unjiu.org/files/jiu_rep_2023_2_english_0.
pdf (accessed 17 March 2024).
15 UNRWA (2021) UNRWA Procurement Manual. 1 November 2021.
Internal document.
16 This is confirmed through a recent review commissioned by the Finn-
ish Government shared with the Review Group; publication forthcoming.
17 United Nations Staff Rules, Rule 8.1 d). Available at: https://policy.
un.org/browse-by-source/staff-rules#Rule%201.1
(accessed 15 April 2024).
18 UNRWA Neutrality Framework, p. 6.
19 UNRWA Ethics Office, “Code of Ethics (ver. 4/2023).” Available at:
www.unrwa.org/sites/default/files/content/resources/unrwa-code-of-
ethics-v4-2023-english_1.pdf (accessed 29 February 2024).
20 UNRWA, “Personal use of social media policy (February 2024);”
“Website and social media guidelines regarding official use (August
2021);” “Website and social media guidelines regarding personal use
(August 2021).” Internal documents.
21 UNRWA, “Standards of conduct.” Available at: www.unrwa.org/pro-
curement/standards-conduct (accessed 29 February 2024).
22 “Executive Office Instruction No. 1, UNRWA Neutrality Framework”
(2017), p. 14 (internal document)
23 UNRWA, “Annex 3 Contract and Conditions of Service for a Daily
Paid Worker.” Internal document.
24 UNRWA, “Code of Ethics.” Available at: https://www.unrwa.org/
sites/default/files/content/resources/unrwa-code-of-ethics-v4-2023-
english_1.pdf (accessed 11 April 2024).
25 UNRWA Ethics Office, “Code of Ethics.” Available at: www.unrwa.
org/sites/default/files/content/resources/unrwa-code-of-ethics-
v4-2023-english_1.pdf (accessed 5 March 2024); “Serving Ethically
– Handbook on Ethics and the Standards of Conduct Applicable to
UNRWA Personnel.” Internal document.
26 UNRWA, “HRD Measures on Neutrality, 11 February 2024:” Interna-
tional staff regulations, cod.i/61/rev.7: 1 January 2018. Available at:
www.unrwa.org/sites/default/files/international_staff_regulations_ef-
fective_1jan2018.pdf (accessed 5 March 2024); Area staff regulations,
Cod./A/59/Rev.25/Amend.120: 01 June 2010. Available at: www.
unrwa.org/sites/default/files/area_staff_regulations_dec2015.pdf (ac-
cessed 5 March 2024).
27 United Nations Security Council, “United Nations Security Council
Consolidated List.” Available at: https://www.un.org/securitycouncil/
content/un-sc-consolidated-list (accessed 11 April 2024).
28 UNRWA, “Standard operating procedures on screening against Unit-
ed Nations Consolidated Sanctions Lists and assessment of UNRWA
counterparts with respect to EU restrictive measures” (2019); “2023
Q&A.” Internal document.
29 UNRWA, “What we do.” Available at: https://www.unrwa.org/what-
we-do/eligibility-registration (accessed 11 April 2014); UNRWA, “Con-
solidated Eligibility and Registration Instructions.” Available at: http://
www.unrwa.org/sites/default/files/2010011995652.pdf; UNRWA, “Ap-
proach to Screening of Beneficiaries: Current issues, challenges, and a
proposed way forward.” Internal document.
30 TNA FGD analysis, “Humanitarian principles training needs assess-
ment:  preliminary analysis of focus group discussions” (November
2023), internal document; Department of Internal Oversight Services
(DIOS), “Audit of screening process against the United Nations sanc-
tion list (formerly known as ‘vetting’),” Ref: DIOS 2023/R00x (May
2023). Internal document.
44
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31 UNRWA defines installations as “buildings, structures, or parts
thereof, that are either owned by, under the control of, or are wholly
or partially occupied or used by UNRWA in connection with its official
purposes.” UNRWA, “Standing operating procedures for integrated as-
sessments.” Internal document.
32 UNRWA, “Standing operating procedures for integrated assess-
ments;” “Standard operating procedures for installation neutrality
inspections” (2017); “Installation integrated assessment 2022;” “Fre-
quently asked questions (FAQ) Version: 0.1 (August 2022)”; “Techni-
cal guidance on new integrated assessments, 2023 release.” Inter-
nal documents.
33 The integrated assessments are conducted by: Installation Manag-
er, Protection Team Leader, Humanitarian Principles Focal Point, Area
Protection Focal Point, Chief Area Officer, Field Director, Senior Hu-
manitarian Principles Coordinator, and Chief of the Protection Division.
The integrated assessments are conducted according to the Executive
Advisory Group decision, 16 March 2022, 2022-01-26-DN-41; UNRWA
“Installation integrated assessment: technical guidance on new inte-
grated assessments” (2023). Internal documents.
34 Executive Advisory Group decision, 16 March 2022, 2022-01-26-DN-
41; UNRWA “Installation integrated assessment: technical guidance on
new integrated assessments” (2023). Internal documents.
35 Each position has distinct and defined responsibilities, including for
escalation of violations of the humanitarian principles. As described in
“Technical instruction on reporting critical incidents within UNRWA to
the Executive Office” (28 September 2020). Internal document.
36 “Integrated assessments of UNRWA installations Q3 2023: 1 July
to 30 September 2023;” “Integrated assessments of UNRWA installa-
tions Q2 2023: 1 April to 30 June 2023;” “Integrated assessments of
UNRWA installations Q3 2023: 1 July to 30 September 2023.” Internal
documents (infographics).
37 UNESCO, “The Recommendation on Education for Peace and Hu-
man Rights, International Understanding, Cooperation, Fundamental
Freedoms, Global Citizenship and Sustainable Development.” Available
at: https://unesdoc.unesco.org/ark:/48223/pf0000386924 (accessed
7 April 2024).
38 Kjersti G. Berg, Jørgen Jensehaugen and Åge A. Tiltnes, “UNR-
WA, funding crisis and the way forward,” CMI report no. 4 (September
2022). Available at: www.cmi.no/publications/8574-unrwa-funding-cri-
sis-and-the-way-forward (accessed 17 March 2024).
39 According to information the Review Group received from UNRWA,
more than 90 per cent of the allegations are raised by the organiza-
tion Impact-SE.
40 Georg Eckert Institute for International Textbook Research, Re-
port on Palestinian Textbooks (2021). Available at: www.gei.de/en/
research/projects/report-on-palestinian-textbooks-paltex (accessed
16 March 2024).
41 US Government Accountability Office Report on UNRWA Text-
books (2018). Available at: https://www.un.org/unispal/wp-content/
uploads/2019/02/USGAOTEXTBKRPT_070219.pdf (accessed 12 April
2024); The Council of Religious Institutions of the Holy Land, “Victims
of Our Own Narratives?” Portrayal of the “Other” in Israeli and Palestin-
ian School Books (2013).
42 Georg Eckert Institute for International Textbook Research, Report
on Palestinian Textbooks (2021). Available at: www.gei.de/en/re-
search/projects/report-on-palestinian-textbooks-paltex (accessed 16
March 2024). According to the Eckert report, in the textbooks for the
academic year 2020/2021, “there is a reduction in the text and imag-
es that have escalatory potential: including the alteration of a specific
teaching unit that included anti-Semitic content by several significant
changes of the narrative.” In addition, the Eckert report notes, “In the
2020 edition of the textbook Islamic Education 5/II this teaching unit
[where antisemitic content was claimed] has been altered in several
passages, thereby reducing the negative  focus  on  Jews.” Finally, the
Eckert report states, “This chapter, which is discussed in detail in Chap-
ter 3.2.1 of this Report with regard to its anti-Semitic references, has
been altered at certain points for the 2020 edition.”
43 UNRWA, “Framework for quality analysis and implementation of
curriculum, fact sheet. January 2023.” Available at: https://www.unr-
wa.org/sites/default/files/curriculum_factsheet_2023.pdf (accessed
17 March 2024).
44 See UNRWA policy on education for human rights, conflict res-
olution and tolerance. Available at: https://www.unrwa.org/sites/
default/files/2013060632316.pdf (accessed 17 March 2024). UNRWA
Remote Learning and
Developing Self-Learning Materials Department of Education UNRWA
HQ (Amman) August 2021 (internal document).
45 UNRWA, “Neutrality Review Manual, Document No: 2021-001.” In-
ternal Document.
46 Chaired by the Deputy Commissioner-General and comprising the
Departments of Education and Legal Affairs, the Protection Division,
the Executive Office, the Director of Strategic Communication and rep-
resentatives of field and representative offices.
47 UNRWA Education Alignment with UN Values and Preventive Meas-
ures, Note on the Monitoring of Quality Assurance Process of Rapid
Review (2023-24 academic year). UNRWA Donor Briefing. Briefing on
UNRWA Review of Palestinian Authority Textbooks 2022/2023, Semes-
ters 1 and 2, Grades 1–10 Revised Version, Internal documents.
48 UNRWA, “Education Department – HQ (A)” and “Critical Thinking
Approach (CTA): A Guide for Educators, April 2023,” Internal docu-
ments. UNRWA, “Curriculum Framework 2013, UNRWA framework for
the analysis and quality implementation of the curriculum.” Available
at:
https://www.unrwa.org/sites/default/files/unrwa_curriculum_
framework_2013.pdf (accessed 11 April 2024); UNRWA, “Framework
for quality analysis and implementation of curriculum, fact sheet. Jan-
uary 2023.” Available at: https://www.unrwa.org/sites/default/files/
curriculum_factsheet_2023.pdf (accessed 17 March 2024).
49 UNRWA, “Whole School Approach to Critical Thinking Practical
Activities: Handbook for UNRWA Teachers, 2021.” Internal document.
This approach is to be understood within the Whole School Approach
that is collective and cooperative, strategic, and inclusive efforts and
actions undertaken by the school community within and outside the
school to improve students’ learning, behaviour, and well-being, in ad-
dition to improving the environment that supports all these efforts and
actions so all practices are evidence-based.
50 UNRWA, “Whole School Approach to Critical Thinking Practical
Activities: Handbook for UNRWA Teachers, 2021.” Internal document.
Critical thinking can accordingly be defined as: “Series of higher stand-
ard-based mental processes that are performed by the student such as
interpretation, analysis, evaluation, inference, explanation, and self-reg-
ulation to delve and dig deeper into a given topic or problem which
requires collecting information and data in several methods and ways
such as observation, experience, thinking/reasoning, and discussion.
The student then processes the information and data separating facts
from opinions, analysing, and interpreting them to conclude evidence
and conjecture alternatives that would help in evaluating the evidence
to ensure their validity based on their assumptions, beliefs, experience,
and structures of their knowledge. The findings of processing infor-
mation are then organized and formulated into decision, judgement,
opinion, solution to a given problem that are logically and scientifically
supported by evidence.” (p. 7).
45
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51 UNRWA, “Digital Learning Platform.” Available at: keeplearning.
unrwa.org/en/ (accessed 16 March 2024).
52 UNRWA, Department of Internal Oversight Services Audit of the
Rapid Review Process, Audit Report (02/2022), Available at: https://
dios.unrwa.org/sites/default/files/results_summary_audit_of_rapid_
review_process_30.03.22.pdf (accessed 16 March 2024); UNRWA, “The
findings of the Rapid Review of the PA Semester 2 textbooks taught in
UNRWA schools in 2022/2023. Grade 1-9 2 March 2023, Annex 2.” In-
ternal document. “The findings of the Rapid Review of the PA Semester
1 textbooks taught in UNRWA schools in 2022/2023 Grade 1-9 Submit-
ted on 10 November 2022, Annex 1.” Internal document. “Briefing on
UNRWA Review of Palestinian Authority Textbooks 2022/2023, Semes-
ters 1 and 2, Grades 1–10 Revised Version.” Internal document.
53 In this regard, it is relevant to note that the UN Special Rapporteur in
the field of cultural rights has stated that: “history teaching should aim
at fostering critical thought, analytic learning and debate; stressing the
complexity of history and should enable a comparative and multi per-
spective approach.” UN Special Rapporteur in the field of cultural rights,
A /68/296, para. 88; United Nations, “A/68/296: Report on the writing
and teaching of history.” Available at: https://www.ohchr.org/en/doc-
uments/thematic-reports/a68296-report-writing-and-teaching-history
(accessed 11 April 2024).
54 Information pollution includes misinformation, disinformation
and malinformation. For example, see UNDP, “Information Integrity.”
Available at: https://www.undp.org/information-integrity (accessed
11 April 2024).
55 UNRWA, “UNRWA Strategy on information and communication
technologies for education (ICT4E) 2022.” Available at: https://www.
unrwa.org/sites/default/files/unrwa_strategy_on_information_and_
communication_technology_for_education_ict4e_07.pdf
(accessed
8 April 2024).
56 United Nations, “Our Common Agenda Policy Brief 8 | Information
Integrity on Digital Platforms.” Available at: https://www.un.org/sites/
un2.un.org/files/our-common-agenda-policy-brief-information-integri-
ty-en.pdf (accessed 5 April 2024).
57 United Nations, “Staff Rules and Regulations of the United Na-
tions (ST/SGB/2017/1).” Available at: https://digitallibrary.un.org/re-
cord/855429?ln=en&v=pdf (accessed 13 April 2024).
58 UNRWA, “Joint Evaluation and Audit of the UNRWA Gender Equality
Strategy 2016-2022.” Available at: https://www.unrwa.org/resources/
dios-and-evaluation/joint-evaluation-and-audit-unrwa-gender-equali-
ty-strategy-2016-2022 (accessed 11 April 2024).
59 As an example, UNESCO provides the Director for Education, and
WHO provides the Director for Health.
60 UNRWA, “What is the Mandate of UNRWA?” Available at: https://
www.unrwa.org/what-mandate-unrwa-0 (accessed 11 April 2024);
United Nations Meetings Coverage and Press Release, “General As-
sembly Adopts 33 Resolutions Recommended by its Fourth Commit-
tee, Including Renewal of UNRWA Mandate until 30 June 2026.” Avail-
able at: https://press.un.org/en/2022/ga12481.doc.htm (accessed
12 April 2024).
61 UNRWA, “Department of internal Oversight Services, Annual Report
2022”, p. 29; available at: https://www.unrwa.org/sites/default/files/
content/resources/annual_report_dios_2022_adcom_11062023.pdf
62 Report of the Commissioner-General of the United Nations Relief
and Works Agency for Palestine Refugees in the Near East 1 Janu-
ary–31 December 2020 (United Nations publication, 2021). Available
at: www.un.org/unispal/document/report-of-the-commissioner-gener-
al-of-unrwa-1-jan-31-dec-2020-a-76-13/ (accessed 16 March 2024).
63 Report of the Commissioner-General of the United Nations Relief
and Works Agency for Palestine Refugees in the Near East: 1 Janu-
ary–31 December 2021 (United Nations publication, 2022). Available
at: www.un.org/unispal/document/report-of-the-commissioner-gener-
al-of-unrwa-1-jan-31-dec-2021-a-77-13/ (accessed 16 March 2024).
64 Report of the Commissioner-General of the United Nations Relief
and Works Agency for Palestine Refugees in the Near East: 1 Janu-
ary–31 December 2022 (United Nations publication, 2023). Available
at: reliefweb.int/report/occupied-palestinian-territory/report-commis-
sioner-general-united-nations-relief-and-works-agency-palestine-ref-
ugees-near-east-1-january-31-december-2022-a7813-enarruzh
(ac-
cessed 16 March 2024).
65 Ibid.
66 Ibid.
67 Ibid.
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XII. Annexes
Annex A: Terms of Reference
Group to Conduct an Independent Review of mechanisms and procedures
to ensure adherence by UNRWA to the humanitarian principle of neutrality
General
1.
The principle of neutrality is one of the four ‘humanitarian prin-
ciples’ adopted by the General Assembly, alongside humanity,
impartiality and independence (General Assembly Resolutions
46/182 and 58/114). Neutrality entails that humanitarians do
not take sides in hostilities and do not engage in controversies
of a political, racial, religious or ideological nature. It is impor-
tant for fostering trust, security and humanitarian access to
populations in need.
Various non-governmental and governmental organizations,
as well as State entities have been making serious allegations
related to the neutrality of Agency personnel, installations and
operations. These allegations have included, most recently, alle-
gations that UNRWA (“Agency”) personnel have participated or
otherwise been involved in the 7 October 2023 attacks in Israel.
In light of the very serious reputational, financial, political and
security implications of the allegations against the Agency’s
neutrality, it is crucial to have a full and independent review to
assess whether the Agency is doing everything within its pow-
er to ensure neutrality and to respond to allegations of serious
breaches when they are made, taking into account the Agen-
cy’s mandate, its capacities and resources and the unique and
frequently difficult operational, political and security context in
which it has to work, particularly in Gaza.
The Secretary-General, in consultation with the Commissioner
General, has accordingly decided to establish an independent
group to carry out that review.
2.
3.
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Composition of the Review Group
4.
(a) Ms. Catherine Colonna — Chair
(b) Raoul Wallenberg Institute (Sweden)
(c) Chr. Michelsen Institute (Norway)
(d) Danish Institute for Human Rights (Denmark)
(e) Secretary from OCHA
5.
The members of the Review Group are independent and
equal with respect to the substance of the review. The Chair
has additional organizational, coordination, and representa-
tive functions.
Identified Tasks
6.
The detailed tasks of the Review Group will be as follows:
a. To identify the mechanisms and procedures that the
Agency currently has in place to ensure neutrality and to
respond to allegations or information indicating that the
principle may have been breached;
b. To ascertain how those mechanisms and procedures
have, or have not, been implemented in practice and
whether every practicable effort has been made to apply
them to their full potential, taking into account the par-
ticular operational, political and security environment in
which the Agency works;
c. To assess the adequacy of those mechanisms and pro-
cedures and whether they are fit for purpose, including
in relation to the management of risks and taking into
account the particular operational, political and security
context in which the Agency works;
d. To make recommendations for the improvement and
strengthening, if necessary, of the mechanisms and
procedures that are currently in place or for the creation
of new and alternative mechanisms and procedures that
would be better fit for purpose, taking into account the
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particular operational, political and security context in
which the Agency works;
e. To produce a report including its findings and recom-
mendations.
7.
While the Review Group may take into account and consider
specific allegations that the principle of neutrality has been
breached, it will not itself investigate any such allegations nor
make any findings of fact in respect of them.
The Review Group will liaise with the Office of Internal Oversight
Services (OIOS), if and as necessary, in order to avoid any preju-
dice to OIOS’s ongoing or future investigations.
8.
Time Frame
9.
The Review Group will complete its assessments and submit its
report in accordance with the following timeframe:
a. 14 February 2024 ― the Review Group will start its work.
b. 14 to 16 February 2024 ― briefings to the Review Group.
c. 20 March 2024 — the Review Group will submit an interim
report to the Secretary-General, through his Chef de Cabinet.
d. 20 April 2024 ― the Review Group will submit its final report
to the Secretary-General, through his Chef de Cabinet.
Administrative and logistic support
10.
The Agency will arrange and provide the necessary adminis-
trative and logistic support to the Review Group, including ac-
commodation, subsistence, transport and security. The Deputy
Commissioner-General (Programmes and Partnerships) will be
in charge of making the necessary arrangements.
Classification
11.
The Review group’s interim and final reports will be marked as
UNCLASSIFIED.
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12.
The Review Group will ensure that all drafts of its interim and
final reports and all communications concerning those reports
are marked as UN STRICTLY CONFIDENTIAL.
13.
The Review Group will ensure the protection of all information
provided to it by outside sources under an expectation of con-
fidentiality.
Additional instructions
14.
The Review Group will be prepared to provide briefings to the
Secretary-General and to the Commissioner-General following
the submission of its interim and final reports.
15.
The Review Group will be prepared to provide a briefing to
the Agency’s donors following the delivery of its interim and
final reports.
16.
Meetings sought by the Review Group with relevant officials of
the Government of Israel and of the Palestinian Authority will be
arranged through UNSCO.
17.
Meetings sought by the Review Group with members of the
Agency’s Advisory Commission will be arranged through the
Deputy Commissioner General (Programmes and Partnerships).
18.
The Review Group will transfer all materials generated or re-
ceived in the course of its work to the Agency’s archives once it
has submitted its report.
Dated: 14 February 2024 | António Guterres, Secretary-General | Place: New York
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2858521_0051.png
Annex B: Overview of documented and alleged violations of neutrality
and inviolability
Neutrality violations registered by UNRWA DIOS since 2017
61
 
According to the DIOS Annual Report 2022 
Breakdown of all investigated cases, including neutrality, (2017–2022)
Category of Cases
Sexual Exploitation and Abuse (SEA)
Sexual Harassment (SH)
Corporal Punishment
Breach of Neutrality
Assault (not CP)
Retaliation
Harassment/Discrimination/Abuse of Power
Recruitment Irregularity
Fraud, Theft & Loss to the Agency
Other Cases
Total
2017
9
3
87
55
13
4
52
13
55
76
367
2018
4
6
62
10
20
2
18
8
43
98
271
2019
10
7
86
9
22
2
52
16
65
74
282
2020
5
3
23
7
9
2
43
10
51
64
172
2021
6
4
23
27
9
3
43
5
49
91
210
2022
5
2
88
18
10
2
28
7
34
84
225
Overview of 2022 investigated cases, including breaches of neutrality
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Breakdown of neutrality cases by field office (2022):
•
•
•
•
•
Gaza: zero cases submitted, no open cases.
West Bank: three cases opened, two cases closed,
one case open.
Lebanon: four cases opened, six cases closed,
13 cases open.
Jordan: six cases opened, six cases closed,
three cases open.
Syria: one case opened, zero cases closed, sev-
en cases open.
Violations of the inviolability of the United Nations
UNRWA Annual Reports to the General Assembly (2020, 2021, 2022) list
breaches of the inviolability of the UN. These reports document that vio-
lations, to a large degree, concern the inviolability of UNRWA installations.
Here we summarize reported incidents in the West Bank and Gaza in 2020,
2021 and 2022. UNRWA protested all these instances of breaches of its
privileges and immunities with the relevant authorities. Reported cases
from Jordan, Syria and Lebanon are not included here for the sake of space.
West Bank
•
In 2020, in the West Bank, including East Jerusalem, one example
was reported of Israeli Security Forces (ISF) entering UNRWA premis-
es, and eight occasions of (for example) tear gas canisters, stun gre-
nades and live ammunition landing on or damaging UNRWA property.
In 2020, no incursions were reported into UNRWA premises by Pales-
tinian militant groups. UNRWA premises and services were disrupted
at least 28 times by forced closures or protests.
62
•
In 2021, at least 11 occasions of tear gas canisters, stun grenades,
plastic coated metal bullets or live ammunition used by the ISF land-
ed in UNRWA premises, including schools. This year, there were three
reported incidents of Palestinian militant groups’ incursions into
52
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UNRWA premises. On 21 occasions, UNRWA premises and services
were disrupted due to forced closures or protests.
63
•
In 2022, UNRWA reported 129 incidents, with 53 cases involving
ammunition landing on or striking an UNRWA installation, affecting
schools. Most incidents happened during exchanges of fire between
Palestinian militant groups and the ISF, but the source of ammunition
is not conclusive. In 48 instances, UNRWA had to close its installa-
tions due to ISF operations or strikes by local communities. UNRWA
installations had to be evacuated seven times to prevent exposing
children to tear gas during ISF operations. There was one reported
instance of unauthorized Palestinian armed forces actors entering
UNRWA premises and four incidents involving the unauthorized en-
trance of ISF into UNRWA premises.
64
Gaza
•
In 2020, ammunition fired by the ISF landed inside or damaged
UNRWA premises twice. One incursion was reported into UNRWA
premises by the de facto authorities in Gaza. Moreover, shrapnel land-
ed inside UNRWA installations as a result of Hamas or other armed
groups. On one occasion, a hand grenade and a military vest were
identified inside an UNRWA school. Bullets from unknown sources hit
UNRWA installations twice.
65
•
In 2021, four incursions by Hamas into UNRWA installations were re-
ported, and two pieces of unexploded ordnance were found in two
UNRWA installations. In January 2021, bullets from an unknown
source hit an UNRWA school, and three schools and a health cen-
tre were affected by an accidental explosion of live ammunition in
an adjacent house in northern Gaza. Fifty-seven other incidents were
reported, related to the hostilities between Israel and Hamas in May
2021, mainly related to Israeli air strikes (injuries, damages). On two
of these occasions, UNRWA discovered two tunnels (the tunnels
were filled). There was one instance of threats from Hamas directed
at senior UNRWA management.
66
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•
In 2022, there were eight incursions into UNRWA installations by Ha-
mas, and a large cavity was discovered under an UNRWA school in
November 2022 (the cavity was filled). In August 2022, an UNRWA
school suffered minor damage due to Israeli fire, and agency per-
sonnel was injured by shrapnel from a nearby Israeli air strike while
guarding an UNRWA school. A rocket fired by a Palestinian militant
group damaged an UNRWA school, but no injuries were reported.
67
54