Creating an integrated society and recognising differences : the role and limits of human rights, with special reference to Europe

Merja Pentikäinen

Creating an Integrated Society and Recognising Differences

The Role and Limits of Human Rights, with Special Reference to Europe

Academic Dissertation to be presented,

with the permission of the Faculty of Law of the University of Lapland, for public discussion in the Esko and Asko Hall

on May 30th 2008, at 12 o´clock.

University of Lapland Faculty of Law

Copyright: Merja Pentikäinen Distributor: Lapland University Press

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tel. + 358 40-821 4242 , fax + 358 16 341 2933 publication@ulapland.

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ISSN 0788-7604 PDF

table of contents

Acknowledgements ...vii

Abbreviations ...ix 1 introduction

:

1.1 Integration – A Topical Issue ...1

1.2 The Concept of Integration ...8

1.3 Focus, Objectives and Methods of the Research...17

1.4 Structure of the Thesis ...22

2 internationalhumanrights norms

2.1 Norms Pertaining to Various Groups ...24

2.1.1 Norms on Minorities...24

2.1.1.1 Cautious Steps by the United Nations ...26

2.1.1.1.1 The International Covenant on Civil and Political Rights and the UN Minority Declaration...26

2.1.1.1.2 Other UN Instruments ...31

2.1.1.2 New Ground Broken by the Organization for Security and Co-operation in Europe ...33

2.1.1.2.1 Remarks on the Characteristics of the OSCE and its Commitments ...33

2.1.1.2.2 OSCE Commitments on Persons Belonging to National Minorities ...36

2.1.1.3 The Council of Europe – Attention to Historical Minority Languages and National Minorities ...41

2.1.1.3.1 The European Charter for Regional or Minority Languages ...41

2.1.1.3.2 The Framework Convention for the Protection of National Minorities ...47

2.1.1.3.3 The CoE Summits ...53

2.1.2 Norms on Indigenous Peoples – Going beyond International Minority Norms .59

2.1.2.1 ILO Instruments ...59

2.1.2.2 Other Instruments ...65

2.1.3 Norms Pertaining to Other Groups ...70

2.1.3.1 Various Groups of Migrants ...70

2.1.3.1.1 Norms on Migrant Workers – From Non-integration towards Integration ...71

2.1.3.1.2 Foreign Residents, Participation and Integration ...79

2.1.3.1.3 Asylum-seekers and Refugees – Repatriation Preferred ...82

2.1.3.2 Women, Children, Persons with Disabilities, and the Elderly ...85

2.1.4 Summary and Conclusions on the Norms Pertaining to Various Groups ...94

2.1.4.1 Questions Addressed...94

2.1.4.2 Scope of Group-specific Norms and Recognising Differences ...102

2.1.4.3 On Incorporation: From Forced Assimilation to Integration or Inclusion ...107

2.2 Norms Addressing Certain Issues ...111

2.2.1 Norms on Racial Discrimination, Racism and Other Forms of Intolerance ...111

2.2.1.1 The United Nations and Its Specialised Agencies ...112

2.2.1.1.1 The International Convention on the Elimination of All Forms of Racial Discrimination ...112

2.2.1.1.2 The UN Declaration on Religion and Belief and the Vienna Document ...117

2.2.1.1.3 The Durban Document ...119

2.2.1.1.4 UNESCO and ILO Documents ...127

2.2.1.2 The Organization for Security and Co-operation in Europe ...132

2.2.1.3 The Council of Europe ...137

2.2.1.3.1 The CoE Summit Documents and the CoE Framework Convention...138

2.2.1.3.2 The European Conference against Racism ...141

2.2.2 Nationality and Trafficking in Human Beings ...145

2.2.3 Summary and Conclusions on the Norms Addressing Certain Issues ...149

2.2.3.1 Questions Addressed ...149

2.2.3.2 Concerns, Challenges and Tensions ...155

2.2.3.3 Incorporation: Inclusion and Integration ...159

2.3 Human Rights Norms: Principles of

General Application and the Issue of Incorporation ...163

2.3.1 Equality and Non-discrimination – the Underpinnings of Human Rights Law ...163

2.3.1.1 Various Models of Equality and Forms of Discrimination ...163

2.3.1.2 Prohibited Grounds of Discrimination and the Human Rights of Non-nationals ...174

2.3.2 Autonomy, Identity, Difference, and Incorporation in(to) Society ...177

3 the european union

,

3.1 Human Rights and Fundamental Freedoms in the European Union ...181

3.2 Focus on Non-Discrimination ...184

3.3 EU Approaches to Integration in(to) Society ...193

3.4 Concluding Remarks ...202

4 threeinternational bodies

4.1 The Advisory Committee of the CoE Framework Convention ...208

4.1.1 Supervisory Function of the Advisory Committee ...208

4.1.2 Groups and Questions Addressed ...209

4.1.3 The Issue of Integration ...220

4.1.3.1

4.1.3.2 Summary of the Major Points concerning Integration ...233

4.2 The European Commission Against Racism and Intolerance ...236

4.2.1 ECRI and the Focus of Its Activities ...236

4.2.2 Groups and Questions Addressed ...240

4.2.3 ECRI and the Issue of Integration ...251

4.2.3.1 ECRI’s Remarks on Integration ...252

4.2.3.2 Summary of ECRI’s Remarks on Integration ...273

4.3 The OSCE High Commissioner on National Minorities ...278

4.3.1 The Role and Mandate of the HCNM ...278

4.3.2 Groups and Questions Addressed ...283

4.3.3 The HCNM and the Issue of Integration ...288

4.3.3.1 Integration and National Minorities ...288

4.3.3.2 Integration and “New” Minorities ...297

4.3.3.3 Summary of the HCNM’s Remarks on Integration ...301

4.4

4.4.1 Addressing the Same Kinds of Groups and Issues: Frequent References to Integration ...303

4.4.2 Elements of Integration Put Forward ...306

4.4.3 Conclusions – Major Differences in the Approaches and the Questions Needing Further Development ...312

5 comparisons

,

5.1 The Concept of Integration in International Human Rights Norms and Practice ...320

5.1.1 Numerous References to Integration ...320

5.1.2 In Search of the Content of Integration ...323

5.1.2.1 Elements Linked to Integration ...324

5.1.2.2 Recognising Differences and Identities: Integration in Relation to Assimilation and Inclusion ...326

5.1.2.3 Tensions, Problems and Challenges ...336

5.2 Concluding Analysis and Remarks...347

5.2.1 Challenge for the European States: Creating an Integrated Society ...347

5.2.2 The Need for Clarification and Further Development of the Concept of Integration ...348

5.2.3 The Need to Clarify the Limits of Tolerance and Respect: The Delicate Issue of Religion ...365

5.2.4 Creating Europe as an Area of Freedom, Security and Justice for All and Redefining the Human Rights Regime ...375

Bibliography ...385

acknowledgements

The publication at hand represents the final phase of the doctoral studies I began at the University of Lapland in 2001. It was then that I joined the research project “Re- thinking legal strategies and ethnic discrimination” (ReStra), funded by the Acad- emy of Finland as part of a larger programme (SYREENI) to study marginalisation, inequality and ethnic relations in Finland.

The path through the research “jungle” – at the end of which one brings the re- sults together in a thesis – is far from straight and easy; it is full of turns and twists, ups and downs. Research work of this kind is also characteristically quite a solitary undertaking, but happily there are a number of persons who have made this “journey”

bearable. Brainstorming sessions on the topic have made the effort worthwhile – and at times extremely stimulating.

Professor Lauri Hannikainen from the University of Turku acted as my supervi- sor and in this role met with patience, among other things, the stubbornness that I showed from time to time when I insisted on doing certain things my way. Profes- sor Kari Hakapää from the University of Lapland was also always there with help and positive support. Professor Rainer Hofmann from the University of Frankfurt and Docent Eyassu Gayim from San Diego State University kindly agreed to be the examiners of my work, and their very helpful comments enabled me to improve the thesis during the home stretch.

The publication could not have been finalised without invaluable help from Richard Foley, who took care of the language checking, and from Tuula Tervas honka, who took responsibility for the various steps needed for turning a manuscript into a book. The layout of the text is the work of Paula Kassinen, who showed great flexibil- ity when it came time to finally submit the material, and Niina Huuskonen put the final touches on the book in designing the cover.

There are many other persons who have lent their support and assistance in the course of doing the thesis. The researchers at the Northern Institute for Environmen- tal and Minority Law of the University of Lapland have always been a part of my “re- search family”, and discussions with them have helped me to refine my thoughts on various research topics considered in the Institute. Particular thanks are due to Timo Koivurova, the head of the Institute, and Tanja Joona, who, among other things, en- abled me to obtain certain materials I needed for my research. Monica Tennberg of the Arctic Centre of the University of Lapland took me on board for some months in 2006–2007 in the INDIPO research project funded by the Academy of Finland.

I was able to enjoy very interesting exchanges of views with colleagues and friends

from other contexts as well. Venla Roth and I had intriguing discussions on the sub- stantive issues concerning international migration and aspects of international law re- lating to the phenomenon. I also benefited from the insights of Timo Makkonen and Reetta Toivanen, with whom I participated in the ReStra project mentioned above. The support I have received over the years from Anja Lindroos has been invaluable. Fur- thermore, I have always cherished the discussions with my friends Melody Karvonen and Sam Karvonen. All of these opportunities to share views have left their mark on my thinking and without doubt are reflected to some extent in the work at hand.

The Library of Parliament in Helsinki provided me with a place to study for many years, and its helpful personnel were an invaluable asset in the course of the research.

I wish to thank Heikki Voutilainen in particular for his help and support. For some time, the Library was also the site of my own academic circle, and innumerable coffee and lunch breaks with Heikki Larmola, Juhani Perttunen and Markku Kiikeri were occasions for extremely interesting and thought-provoking discussions on theoretical as well as practical issues in international relations, history, politics and law.

I would also like to thank Pirjo Kleemola-Juntunen, Assistant in International Law at the University of Lapland, who was always helpful when I needed information on doctoral studies, for instance. Juha Raitio, Professor of EU Law at the University of Helsinki, kindly helped me in my efforts to make sense of the EU terminology and concepts. Naturally I bear the sole responsibility if I have not got them right. Aapo Ojala was always available whenever I needed assistance with the technical aspects of my work, i.e. with computers and the like. On the home front, Esa showed extreme patience when I submerged myself in my academic “adventure”, withdrawing into the world of my own thoughts, and dealt admirably with the ensuing absent-mindedness where almost every aspect of “ordinary life” was concerned.

Last, but not least, my thanks go to the organisations that have provided me with the financial assistance that has been indispensable to completing the thesis. The Academy of Finland provided funding in conjunction with the ReStra project that enabled me to make a start, and contributed later through the opportunity I had to work in the INDIPO project. The following foundations also granted financial assis- tance: Jenny ja Antti Wihurin rahasto, E.J. Sariolan säätiö, Suomen Kulttuurirahasto (the Finnish Cultural Foundation), Olga ja Kaarle Oskari Laitisen säätiö, Suomalai- nen Konkordia-liitto, Emil Aaltosen säätiö and Alfred Kordelinin yleinen edistys- ja sivistysrahasto. The grant I received from the rector of the University of Lapland was also an important financial contribution.

All in all, I am glad that this stage of my research is now completed, and look forward to channelling my energy and efforts towards new challenges.

Nummenkylä, April 2008 Merja Pentikäinen

abbreviations

AC Advisory Committee

ADU Anti-Discrimination Unit of the Office of the UNHCHR AMID Akademiet för Migrationsstudier in Danmark; Academy for

Migration Studies in Denmark

CBPs Common Basic Principles

CEDAW Convention on the Elimination of All Forms of Discrimina- tion against Women

CEDAW Committee Committee on the Elimination of All Forms of Discrimina- tion against Women

CERD Committee on the Elimination of Racial Discrimination

CoE Council of Europe

CPRSI Contact Point for Roma and Sinti Issues

CSCE Conference on Security and Co-operation in Europe EBLUL European Bureau for Lesser-Used Languages

EC European Community

ECHR Convention for the Protection of Human Rights and Funda- mental Freedoms (European Convention on Human Rights)

ECJ European Court of Justice

ECR European Court Reports

ECRI European Commission against Racism and Intolerance EESC European Economic and Social Committee

EHRR European Human Rights Reports

ETS European Treaty Series

EU European Union

EUMC European Monitoring Centre on Racism and Xeno phobia

FRA Fundamental Rights Agency

FYROM Former Yugoslav Republic of Macedonia

GPR General Policy Recommendation

HCNM High Commissioner on National Minorities HDIM Human Dimension Implementation Meeting

HRC Human Rights Committee

ICCPR International Covenant on Civil and Political Rights

ICERD International Convention on the Elimination of All Forms of Racial Discrimination

ICESCR International Covenant on Economic, Social and Cultural Rights

ILO International Labour Organization IOM International Organization for Migration IWGIA International Work Group for Indigenous Affairs

NGO Non-governmental organisation

OECD Organisation for Economic Co-operation and Development ODIHR Office for Democratic Institutions and Human Rights OHCHR Office of the UN High Commissioner for Human Rights OJ Official Journal of the European Union

OSCE Organization for Security and Co-operation in Europe RFoM Representative on Freedom of the Media

TEC Treaty establishing the European Community

TEU Treaty on European Union

UDHR Universal Declaration of Human Rights

UK United Kingdom

UN United Nations

UNDP United Nations Development Programme

UNESCO UN Educational, Scientific and Cultural Organization

UNGA UN General Assembly

UNHCHR UN High Commissioner for Human Rights UNHCR UN High Commissioner for Refugees UNTS United Nations Treaty Series

US United States

USA United States of America

WCAR World Conference against Racism

WGM Working Group on Minorities

WHO World Health Organization

WTO World Trade Organization

1

:

1.1 Integration – A Topical Issue

Diversity and difference are an inherent part of human life. Each person is unique, having his or her individual characteristics, and when individuals come together they in turn form groups with distinctive characteristics and dynamics where di- versity and differences are concerned. Societies have always been essentially diverse in the sense that they have been composed of various groups characterised, for in- stance, by ethnic, cultural, linguistic or religious differences. Some of these groups have long historical roots in their respective societies, while others have emerged from more recent migratory flows.

People have always migrated, and for a variety of reasons. In addition to migrat- ing voluntarily, people have been forced to leave their homes due to wars, persecu- tions, natural disasters, and similar events. People’s international mobility has in- creased tremendously over the last few decades, particularly since the mid- twentieth century; in the present era of globalisation, individuals are on the move more than ever before, with migratory flows becoming increasingly multifaceted.¹ Migration has also become one of the most important transformative forces of contempo- rary societies. Historically, particularly from the nineteenth century to the Second World War, Europe was the place people left, emigrating to North America, for instance, in the hope of better living conditions or in order to flee political or re- ligious persecutions. A clear change took place in the second half of the twentieth century, when large parts of Europe experienced a historical shift from emigration to immigration.² The aftermath of the Second World War created a demand for for- eign labour, and many European states viewed immigration as the ideal solution to acute post-war labour shortages when the rebuilding of shattered societies created an economic boom. Western European employers imported workers from abroad and countries like Switzerland, France, and Belgium first turned to Italy and the Iberian Peninsula, then to the former Yugoslavia and Greece. France, Britain, and the Netherlands recruited labour from their disintegrating empires in North Africa, South Asia, and the Caribbean.³

1. Migrations of various kinds were also key factors in colonialism, industrialisation and na- tion-building. Castles (2005), p. 278.

2. IOM (2005), p. 141.

3. Ireland (2004), p. 2.

The direction of labour recruitment was also influenced by the beginning of the Cold War, which in practice halted the movement of people and contacts among them across the Iron Curtain, i.e. between the Soviet-led Eastern bloc and the US- led Western bloc. For instance, when the Berlin Wall – the symbol of Cold War Europe – prevented West Germany from tapping labour reserves in East Germany, the country recruited workers from elsewhere, Turkey in particular, resulting in the creation of the German “guest worker” model of labour recruitment.

The drastic deterioration of the world economy in the early 1970s resulted every- where in the imposition of bans on new immigration. It also became clear that most of the immigrant workers who had earlier come to Western Europe to fill the la- bour shortage did not intend to leave. This was contrary to what was expected in the receiving countries; that is, instead of workers of foreign background staying temporarily, their residence resulted in more permanent settlement.⁴ In fact, the influx to Western Europe continued when the family members of immigrant work- ers joined them.⁵ In addition, Europe received an increasing number of refugees and asylum-seekers.⁶ These various inflows of immigrants involved a more diverse collection of national groups than had been experienced earlier in Europe.⁷ The in- ternational mobility of people received a “boost” in Europe in the late 1990s, when the end of the Cold War enabled freer movement of people from Eastern Europe to the West. The breakdown of the bi-polar power constellation of the Cold War seemed to open the floodgates for vast new population flows in other parts of the world as well.⁸ Consequently, at the beginning of the 1990s, international migration emerged as one of the key issues in international politics.⁹

With the arrival of the new millennium, and the realisation that Europe is grey- ing, European states have regained their interest in receiving new immigrants to fulfil the needs of their labour market. As a result, in recent years European states have reassumed their active policies of (even mass) recruitment of immigrant labour.

The enlargement of the European Union (EU) in May 2004 by ten new members and beyond the Cold War borders into Eastern Europe marked a historical move

4. Castles (2005), p. 278.

5. For some time, and up until the end of the 1990s, family reunification was the major pat- tern of immigration in Europe, including the EU area. See e.g. the Commission Commu- nication on a Community Immigration Policy (2000), p. 11. Castles has pointed out that in the last half century, the following three types of primary migration have been the most common: permanent settlement migration, temporary labour migration, and refugee move- ments. Each of these frequently led to family reunion, which then often became the largest flow as a movement matured. Castles (2005), p. 284.

6. Ireland (2004), p. 2.

7. Ibid.

8. The final decade of the 20th century also witnessed more newcomers arriving in the US than at any other point in its history. Kivisto (2005b), p. 3.

9. Castles (2005), p. 277.

towards freer movement of people across borders in Europe. Since this enlargement, hundreds of thousands of nationals of the new EU member states have moved to the older member states, particularly for employment purposes.¹⁰ Where the direction of immigration was once largely from the East towards the West, Central Europe has increasingly become the recipient of new immigration.¹¹ A general labour short- age in the EU area has meant that third-country nationals, particularly high-skilled persons, have become objects of more active recruitment efforts by the EU states.

Even as the promotion of labour-based immigration has reappeared on the agen- das of European governments in recent years and become one of the stated policies of the EU, the 1990s saw the very same states (including the EU states) begin to restrict their asylum policies and laws.¹² Combating undocumented migration has also become a prominent issue on both the national and international agendas of many states, as a great number of migrants, for example those entering the EU, come via irregular routes.¹³

Nowadays European societies include a variety of groups of immigrant back- ground such as former migrant and colonial labourers and their family members, (im)migrant workers, modern job-seekers, cosmopolitans working for transnational corporations and international organisations, students, refugees and asylum-seekers and undocumented immigrants. The last include unauthorised migrants and victims of trafficking, who usually end up in the unregulated (black) labour market. All these people have become de facto members of their “host” societies. The trend is also estimated to continue; that is, permanent migration, temporary labour migra- tion, student flows and irregular migration will all grow.¹⁴ The patterns of migration are also changing rapidly. Today more people are moving temporarily, often stay- ing longer, but then returning to their countries of origin. With increased tempo- rary migration, particularly of highly skilled persons, voluntary return has become a major feature of migration in recent years.¹⁵ Characteristic of modern migration is

10. IOM (2005), pp. 146–147. EU membership also signified the extension of the rights linked to EU citizenship to the nationals of the new EU states. These rights primarily include freer movement and residence rights within the EU as workers, students and family members.

For more, see infra chapter 3.2. Many older member states nevertheless imposed some re- strictions (e.g. in the form of transitional periods) on the free movement of workers, as they feared an influx of workers from the new member states into their labour markets. Simi- larly, when Bulgaria and Romania became EU members at the beginning of 2007, a number of the EU states restricted the free movement of workers from these countries.

11. IOM (2005), pp. 146 and 152. See also the remarks infra in this section.

12. EESC (2002), p. 18.

13. Estimates of this kind of immigration into the EU vary from 500,000 people per year up- wards. See e.g. the Commission Communication on a Community Immigration Policy (2000), p. 13.

14. IOM (2005), p. 301.

15. Ibid., p. 14. Seasonal workers and transfrontier workers are among those considered tempo- rary workers.

that the mobility of low-skilled workers is more restricted than that of high-skilled workers.¹⁶ In general, the contemporary flows of migration are characterised by the diversification, proliferation, and intermingling of types of flows. Various forms of migration have become closely linked and interdependent. Officially encouraged flows tend to stimulate irregular movements; permanent and temporary migration cannot be clearly distinguished and tend to stimulate each other.¹⁷ Migration in the era of globalisation is also characterised by new forms of attachments that un- dermine the traditional nation-state-based assumptions of belonging. As a conse- quence, issues such as transnationalism and hybrid identities of individuals have ap- peared in contemporary discussions on migration.

Women are estimated to comprise approximately half of the migrant population, particularly in the advanced industrialised countries.¹⁸ Women and men also circu- late differently in the global economy, with women predominantly entering the ser- vice and welfare sectors. Women feature in skilled migration streams, particularly when admission policies are specifically developed for the occupations often held by women, and consequently have been recruited particularly as nurses and carers. In the area of forced (involuntary) migration, women make up the majority of victims of trafficking in human beings in the world and of persons internally displaced by conflicts.¹⁹ Women also comprise a significant proportion of the world’s refugees.²⁰

The post-1945 developments in migration have resulted in the creation of in- creasingly multicultural and multiethnic societies in Europe. This demographic change has not, however, taken place without problems. Immigration, especially on a large scale, almost unavoidably creates tensions or “shocks” in societies due to its transformative force, which produces profound and also unanticipated changes in the receiving societies and in inter-group relations within them.²¹ An increasing multicultural and multiethnic reality has also triggered high levels of discomfort among Europeans. The economic recession of the 1970s fuelled the rise of racist and xenophobic tendencies and the spread of anti-immigrant sentiment across Europe,

16. Ibid., p. 210. See also the remarks on the EU infra in chapter 3.

17. Castles (2005), pp. 284–286. Regarding newer types of migration flows, Castles refers to return migration as moving increasingly towards temporary or circulatory migration and retirement migration.

18. IOM (2005), p. 13.

19. Ibid., p. 15. IOM has also noted that, despite the heavy impacts of conflicts on women, women are still generally not invited to the peace negotiation tables. Ibid.

20. Often there are no data available by sex, but roughly half of the refugee population is fe- male. The proportions vary greatly depending on the refugee situations; e.g. in mass influx situations, the proportion of female refugees tends to be around 50 per cent. The proportion of females among asylum-seekers, however, is significantly lower in both developing and developed countries. UNHCR (2007), p. 9.

21. Immigration also produces social changes in sending societies and among immigrants them- selves and their descendants. Rumbaut (2005), p. 157. Migration is viewed as one of the key forces of social transformation in the contemporary world. Castles (2005), pp. 277–278.

and the beginning of the new millennium has been characterised by the persistence and even intensification of racist and xenophobic incidents and views. European so- cieties are facing an increasing number of tensions and even conflicts along ethnic lines. These modern-day conflicts are also characteristically of an intra-state nature, one recent concrete example being the violent conflicts in a number of French cities in autumn 2005 involving youth of immigrant background in particular.

In today’s globalised world, economic structures are changing rapidly, with a variety of simultaneous trends heightening the challenge of building and maintain- ing stable societies. In Europe, for instance, there is an increase in demand for new labour in many sectors of the economy, but in a number of sectors employees are being laid off. Many jobs, particularly in Western European states, tend to flee from Western Europe to Eastern Europe and beyond to Asia, which creates economic insecurity among Western Europeans. Their insecurity may also be fuelled by the increasing recruitment of non-Western Europeans to Western Europe, a trend of- ten prompted by the de facto labour cost differential. This situation, which reflects structural problems in the labour markets in Europe, seems to be fertile ground for the development of even fierce anti- immigrant and anti-foreigner signals and reactions. The situation may be, and in practice is, exploited by nationalist politi- cal movements, and populist politicians are tempted to exploit the uncertainty and their constituents’ fear for their own political benefits, fuelling tensions along ethnic lines. The need for immigrant labour and the simultaneous rise of xenophobic and racist attitudes is a real and acute challenge in contemporary European societies, one requiring prompt and determined actions.

In addition to new challenges relating to the increase in populations of immi- grant origin, the past fifteen years have witnessed spirited discussions on the situ- ation of persons belonging to older (traditional) minorities. After the fall of the Iron Curtain, demands came to the fore – and acquired political force – calling for the recognition of the specific characteristics of many minorities that had come to existence when state borders were redrawn following the two world wars and the Cold War. This also came to be reflected in international norms, when at the end of the 1980s – and particularly in the course of the 1990s – states accepted a number of international norms specifically pertaining to minorities within the auspices of the Conference on Security and Co-operation in Europe (CSCE; subsequently the OSCE),²² the United Nations (UN) and the Council of Europe (CoE). On-going, acute minority-related challenges in the Balkans and numerous other minority ten- sions throughout Europe remind us that minority questions not linked to recent migration are also constantly relevant. Many older minorities have presented in-

22. See the remarks on the change of the name of the CSCE into the OSCE infra in chapter 2.1.1.2.1.

creasingly vocal demands for the recognition of their particular characteristics,²³ a development has, for example, contributed to paying increasing – and highly needed – attention to the vulnerable situation of the Roma.²⁴ More active debates in the area of minority protection have resulted in the creation of international standards on minorities. In the course of the last two decades, international regulation con- cerning indigenous peoples has taken steps forward as well.

The increased cross-border mobility of individuals is rendering societies more diverse, resulting in the emergence of “new” minorities. This trend, coupled with intensified demands for recognition by historical minorities and indigenous peoples, means that accommodating various groups – in practice accommodating differences and managing diversity – is among the important contemporary challenges to be addressed by governments. Due to an estimated increasingly positive migration bal- ance in the European states,²⁵ migration remains a key topic and plays a heightened role in public and political debates across Europe; accommodating immigrant- origin populations in particular is destined to remain at the top of the list of political priorities in Europe. The European continent’s still increasing multiethnic reality means that the issues of tolerance, inclusion, equality, and effective inter-group rela- tions are not just interesting theoretical issues but crucial components of European societies that will determine how democratic and resilient these societies will be over the long term.²⁶ The presence of large and diverse immigrant-origin communi- ties has shifted debates towards the issues of identity, social order, crime, and the use of public resources. Debates and disputes have also frequently revolved around the issue of ethnicity.²⁷ In addition, the awakening of the interests of “older” minor- ities has intensified the debates on accommodation, or incorporation into society, of persons belonging to various groups as well as on identity and social cohesion. The

23. Ireland (2004), p. 3.

24. Regarding the term “Roma”, it can be observed that the Roma are referred to in various ways in different contexts. For example, the OSCE uses the term “Roma and Sinti”; CoE documents often refer to “Roma/Gypsies”. One may also find the term “Travellers”. The Durban Document of the third World Conference against Racism refers to “Roma/Gyp- sies/Sinti/Travellers”. In this research, the term “Roma” is used as a general term to refer to all possible categories of Romani people.

25. Today most European states have a positive migration balance. Europe, like most other re- gions of the world, faces demographic ageing due to increasing life expectancies. However, unlike other regions, almost all countries in Europe are experiencing below-replacement fertility rates. Consequently, the pace of demographic ageing is greatly accelerated, and mi- gration is viewed as playing a more prominent role for population growth in Europe than in any other region in the world. The IOM has estimated that during the 21st century, for demographic and economic reasons, all present and future EU member states will either remain or become immigration countries. IOM (2005), pp. 146 and 152.

26. Ireland (2004), pp. 3–4.

27. Ibid., p. 2. Ireland notes that ethnicity belongs to the set of concepts widely used but sel- dom defined in the field of migration.

issues of security, stability and the unity of states also figure in these various discus- sions.

As a result of these developments, the integration of individuals belonging to various groups, particularly those of immigrant background, has recently emerged as a high-level political issue in Europe, including within the EU. In addition to the integration of newcomers, the focus in the area of migration has clearly shifted from a preoccupation with asylum issues to economic migration and irregular migrants.

Increasing cross-border population mobility in the era of globalisation and its cor- ollary – processes of community formation leading to social and cultural changes – are crucial considerations for states in assessing future perspectives.²⁸

The relationship and approach to Islam in Europe has created a challenge of its own.²⁹ The terrorist attacks on the United States (US) in September 2001 not only propelled anti-terrorist actions to the centre of inter-state agendas but also resulted in unprecedented attention to the situation of Muslims in the Western World, in- cluding Europe. Muslim immigration and integration has triggered vivid exchanges of views, which have intensified after a number of violent incidents in Europe, such as the assassination of documentary director Theo van Gogh in the Netherlands in November 2004 and the suicide bombings in London in July 2005: the perpetra- tors of both incidents were found to be of Muslim background, but also persons who had been born in Europe. Policymakers across Europe appear to be alarmed over Islamic fundamentalism and dangerous Islamic “parallel” societies.³⁰ Terrorist attacks have also resulted in a tightening of national immigration laws and in the promotion of national security to a major concern in the immigration policies in many countries.³¹ Another result has been increasing calls for stringent restrictions on Muslim immigration in particular.³²

The question of how to address issues relating to religion and questions having religious underpinnings seems have given rise to many particular challenges. The outcry triggered by the caricatures of the Prophet Muhammad published in a Dan- ish newspaper (Jyllands-Posten) in autumn 2005 bears witness to the delicate, even explosive, nature of issues having religious dimensions. Contemporary religiously motivated tensions have also come to the fore in debates on the use of headscarves by Muslim women in a number of European states, in particular France, Germany and Turkey. The incident in Denmark brought to the fore issues related in particu-

28. Castles (2005), pp. 277–278.

29. Ireland (2004), p. 3.

30. Ibid., pp. 3, 95 and 110. Ireland describes debates in Germany, in the cities of Bremen and Berlin, among others. See pp. 60–115.

31. IOM (2005), pp. 14, 16 and 205. For example, many EU states have recently tightened the integration requirements for migrants. See also ibid., pp. 148–149 and the remarks infra in chapter 3.3.

32. Ireland (2004), p. 1.

lar to freedom of expression and its corollary, the freedom of the media, while the question of headscarves revolves around the complex questions of freedom of reli- gion, human rights of women and the limits states are allowed to set on individuals’

behaviour and actions in the public sphere.

While the issues of recognising and accommodating differences, as well as man- aging diversity, have been closely linked to migrants, old minorities and indigenous peoples, it must not be forgotten that the question of differences – including the is- sue of recognising different needs and concerns of individuals or groups of individu- als – applies to other groups as well. The adoption of international norms on such groups as women, children, persons with disabilities and the elderly recognises the need to pay specific attention to persons belonging to these groups.

1.2 The Concept of Integration

The term “integration” has become an extremely common one in contemporary dis- cussions, a fashionable expression that is used in various contexts. One finds refer- ences to such expressions as European integration, African integration, market in- tegration, economic integration, political integration, integration of various groups such as immigrants, minorities, women, children, persons with disabilities, refugees and victims of trafficking. The present research draws attention to integration at the societal level and particularly to how the issue is considered when the incorporation in(to) society of individuals belonging to various groups is concerned. More specifi- cally, as will be discussed in more detail below, the focus of this research is on hu- man rights, an area in which integration has also become a slogan in recent years.

An English dictionary of general usage states that “to integrate” means “to com- bine or form (a part or parts) into a whole”, “to bring or come into equal member- ship of a community”.³³ According to a British dictionary focussing on the terms relating to race and ethnic relations, “integration”

describes a condition in which different ethnic groups are able to maintain group boundaries and uniqueness, while participating equally in the essential processes of production, distribution and government. Cultural diversity is sustained without the implication that some groups will have greater access to scarce resources than others. For a society to be fully integrated, it must remove ethnic hierarchies, which permit differential access and it must encourage all groups’ contributions to the social whole. …The contrast with assimilation is important: far from facilitating

33. Oxford Paperback Dictionary (1988). See also the references to the definitions of “integra- tion” and “assimilation” in American English dictionaries infra in this section.

an absorption of one culture by another, integration entails the retention or even strengthening of differences of ethnic groups.³⁴

Although some states have expressly addressed the issue of integration in their na- tional legislation, particularly the integration of immigrants,³⁵ and the concept also appears in some international human rights conventions, integration is not a legal concept. In fact, many contexts in which the term “integration” is employed, as well as the terminology itself, suggest that integration is not a static concept, but a pro- cess having cultural and structural aspects with very complex interrelationships.³⁶

The term “integration” has been intensively considered within the social sciences and in the context of (im)migration, where it has been seen as describing primarily the process of how immigrants and the host community grow or should grow closer to one another or how newcomers become members of an existing socio-political community (such as a nation-state).³⁷ Whilst the differentiation of these process- es has become standard, there is nevertheless no uniform terminology to describe them.³⁸ In these discussions, in addition to the concept of integration, one comes across such concepts as assimilation, exclusion, separation, segregation, marginali- sation, incorporation, inclusion, acculturation, and accommodation. Furthermore, these concepts have links to multiculturalism, (cultural) diversity, pluralism/plural- ity, belonging, nationality, citizenship, identity, social cohesion and stability.³⁹ The essential question of recognising and accommodating differences appears to under- lie many of these concepts and their analyses.

34. Dictionary of Race and Ethnic Relations (1996), pp. 172–173. The dictionary notes that in Britain integration has been a policy ideal since 1966, and it is viewed as “not a flattening process of assimilation, but as equal opportunity accompanied by cultural diversity in an at- mosphere of mutual tolerance”. The popular metaphor for assimilation has been the melting pot; for integration it is the salad bowl, with each ingredient, separable and distinguishable, but no less valuable than the others. The dictionary also points out that Canada has favoured the concept of an ethnic mosaic, with the different pieces of society joined together in one ar- rangement. In some societies, such as Belgium, Canada, and Switzerland, institutional provi- sions are made to ensure an ethnically proportionate distribution of resources, thus protecting cultural differences while keeping groups integrated into the whole. Consequently, integration means more than coexistence: it implies an active participation of all groups and an agreement on the appropriate methods of organising the allocation of power, privileges, rights, goods, and services without compromising cultural differences. Ibid.

35. See also Kälin (2003), p. 271.

36. Ibid., pp. 271–272. Ireland has pointed out that the “slippery” concept of integration is tricky to define, analyse and explain. Ireland (2004), p. 17.

37. See also e.g. Martikainen (2005), p. 2.

38. Ibid., and Kälin (2003), pp. 271–272.

39. IOM has asserted that integration touches on the issues of culture and belonging, national- ity, identity and citizenship that are critical for any society seeking to ensure social stability in an increasingly pluralistic world. IOM (2005), p. 322.

In various attempts to describe the concept of integration, integration is often linked particularly to the concept of assimilation.⁴⁰ Sometimes the two are viewed as opposites of sorts.⁴¹ A distinction is drawn between assimilation and integra- tion by linking the former to cultural similarity and the latter to a certain quality of social relations. In this model, assimilation has been described as the process of becoming equal to the natives in the sphere of cultural identity and in patterns of behaviour. Thus, the concept of assimilation refers to the tendentially complete elimination of cultural and behavioural differences between natives and immigrants.

Of central importance in achieving this state of affairs is the process of socialisa- tion and the learning of the language, norms and values that are dominant in the new society. Integration, for its part, is viewed as the process of becoming a part of the social life in the host society. Through integration immigrants gain access to a permanent and relatively complex participation in the different spheres of action and interaction in the host society. More concretely, integration is the process of be- coming similar to the natives in terms of achieving a variety of socially distributed valuable resources.⁴²

Many models envisage a complex relation between integration and assimila- tion, and integration has been divided into various subcategories such as structural, economic and social integration.⁴³ In sociological studies, one finds a division into cognitive, social and structural integration, and integration with regard to identi- fication.⁴⁴ Integration has also been described as having structural and political-

40. See e.g. the remarks on integration presented in the Dictionary of Race and Ethnic Rela- tions supra. The dictionary notes that assimilation is the process of becoming similar, and that due to their complexity, processes of assimilation need to be studied on the individual and the group levels with a focus on specific forms of behaviour seen in their full political and social context. Dictionary of Race and Ethnic Relations (1996), pp. 43–45.

41. See e.g. the use of terms in Britain and the references to the remarks in the Dictionary of Race and Ethnic Relations supra.

42. Diaz (1995), pp. 200–201.

43. Integration is viewed as denoting the incorporation of migrants into, and their participation in the structures of the host society on all levels; this process is termed structural or social integration, which can be further broken down into economic integration, integration into the educational system, and social integration. Economic integration denotes access to economic opportunities, in particular labour, of all kinds and on all levels; integration into the educa- tional system signifies access to non-segregated primary schools and to higher education; and social integration relates to access to the status system of the host society. In this scheme, exclusion, or marginalisation, is viewed as the opposite of structural and social integration.

Cultural assimilation describes the process of growing participation in the culture and values of the host society. It leads to the cultural absorption of migrants into the host society, mak- ing cultural differences disappear to a large extent. This requires migrants to give up their cultural identity and take on, in the sense of acculturation, the values and behaviours of the host society. The opposite of cultural assimilation is cultural diversity or, as it is often called, multiculturalism. Kälin (2003), p. 272.

44. Davy has pointed out that sociological studies distinguish four areas of integration: skills and knowledge (cognitive integration), personal relationships (social integration), positions

cultural dimensions; the relationship between these two dimensions is not straight- forward and policymakers have often stressed one aspect more than the other, with major consequences for ethnic relations.⁴⁵

One also encounters definitions of the term “integration”. For instance, in the area of immigration, integration has been seen as signifying “bringing immigrants’

rights and duties, as well as access to goods, services and means of civic participa- tion, progressively into the line with those of the rest of the population, under con- ditions of equal opportunities and treatment”. This civic, rather than cultural, vision of social integration is observed to go hand in hand with a positive appreciation of cultural diversity.⁴⁶

The following definition of integration has been put forward with reference to refugees:

A long-term process of change which places demands on both receiving societ- ies and the refugees and/or communities. From a refugee perspective, it requires a preparedness to adapt to the lifestyle of the host society without having to lose one’s own cultural identity. From the point of view of the host society, integration requires a willingness to adapt public institutions to changes in the population pro- file, accept refugees as part of the national community, and take action to facilitate access to resources and decision-making processes.⁴⁷

One definition presented in the area of religious studies⁴⁸ uses integration as a gen- eral concept and defines it as “the processes by which individual and groups of im- migrants are incorporated into various social arenas and segments of the new host society. Integration is a two-way process whereby both the immigrants and the host society adapt new features as a result of their interaction. Integration may also have transnational dimensions”.⁴⁹ This definition distinguishes three arenas of integra- tion: cultural, structural and political integration, and differentiates integration from assimilation, acculturation and multiculturalism.⁵⁰

in society (structural integration), and attachment to the country (integration with regard to identification). Davy (2005), p. 128, n. 32.

45. The structural dimension refers to integration in terms of the labour market, education and training, housing, and social services; the political-cultural dimension refers to formal and informal modes of participation, inclusion, and cultural exchange. Ireland (2004), pp. 17–18.

46. EESC (2002), p. 69.

47. The definition is that given by Peer Baneke, the Secretary General of the European Council on Refugees and Exiles (ECRE) and quoted in the Report of the European Conference on the Integration of Refugees (1999), p. 7.

48. See also the remarks on the increased interest of scholars of religion in integration issues infra in chapter 5.2.2.

49. Martikainen (2005), p. 3.

50. It has also been asserted that both assimilation and acculturation place more emphasis on

“becoming alike”, while multiculturalism pays too much attention to difference. Ibid., pp. 3–4.

Whilst Martikainen views his definition of integration as neutral with regard to the outcomes

In addition to discussing the concept of integration (and its neighbouring con- cepts) in the context of the process through which newcomers become members of an existing socio-political community, integration has also been considered from the viewpoint of both the immigrant and society. When the viewpoint on integra- tion is that of the immigrants, the options available to them have been considered in, among other contexts, social-psychological models of immigrant acculturation.

According to one model presented in this regard, immigrants can adopt four differ- ent acculturation strategies: assimilation, integration, separation (segregation) and marginalisation. Assimilation means replacing one’s previous identity with that of the new host society, and integration refers to the capacity to access aspects of the dominant culture while simultaneously retaining an ethnic identity. By separation a group also retains its own culture, but does not want to have contacts with the dominant one, and segregation refers to a society’s policy of exclusion. Marginalisa- tion implies losing one’s cultural background but being simultaneously denied ac- cess to the dominant culture. This model has been criticised for being based on simplified assumptions, but has been credited with rightly pointing to the agency and capacity of the immigrants to make choices themselves.⁵¹

From society’s viewpoint, “integration” (as well as assimilation) appears in con- nection with policy options for states in the area of immigration settlement. These policy options have been synthesised in theoretical models on the process by which immigrants settle in a new host society created by authors who have studied states receiving considerable numbers of immigrants. There exist a number of such mod- els and different authors also label and group various options somewhat differently.

These models show different approaches to the relationship between integration and assimilation. In some, integration is viewed as an umbrella notion for describing various policy options.

It has been pointed out that although no country follows a single model strictly, the polices of various states can often be traced to one of the following models, which shape national policies in a manner that clearly differentiates countries from each other: (1) Assimilation to the dominant culture based on common civic values, in which the ideal is that immigrants become full citizens indistinguishable from the majority population. (2) Creation of a common culture in the sense of a “melting pot”, with immigrants having to accept, but also to contribute to, a common culture based on civic virtues. Cultural diversity is relegated to the private sphere, where it may flourish. (3) Multiculturalism, i.e. the protection or even encouragement of cultural diversity in not only the private but also the public sphere. Immigrants

of the process itself, he also points out that various concepts (such as assimilation, accultura- tion, multiculturalism and even exclusion) are often used to imply normative ideas about the desired outcome of the process of integration. Ibid., pp. 2 and 4.

51. Ibid., p. 5. Martikainen refers to the model created by John Berry.

need not give up their culture but all are obliged to embrace the ideal of tolerance vis-à-vis other ways of life. (4) Separation is a situation in which immigrants do not have to assimilate to the dominant culture because they are not expected to re- main for long, but, at the same time, are denied social integration to a large extent.

Full social integration is only granted once the immigrants have fully assimilated to the dominant cultural patterns of the country.⁵² The general integration policies implemented by states and set out by the International Organization for Migration (IOM) resemble this characterisation, albeit with some differences in the use of terms. The IOM has listed four general integration approaches aimed at permanent and regular migrants: assimilation, segregation, integration and multiculturalism.

In this framework, integration is linked to the “melting pot” model.⁵³

Another way put forward to describe the approaches available to states to in- corporate immigrants into society is to group them into three categories: assimi- lation, differential exclusion, and multiculturalism.⁵⁴ As a mode of incorporation, assimilation means encouraging immigrants to learn the national language and to fully adopt the social and cultural practices of the receiving community. This also involves a transfer of allegiance from the place of birth to the new country and the adoption of a new national identity. In the differential exclusion model, migrants are integrated temporarily into certain societal subsystems, such as the labour mar- ket and limited welfare entitlements, but are excluded from others, such as political participation and the national culture. Citizenship is not an option. Both assimila- tion and differential exclusion share the view that immigration should not bring about significant changes in the receiving society. Such beliefs in the controllability of ethnic difference could be sustained in the past, but began to be questioned in

52. Assimilation to the dominant culture based on common civic values is also referred to as the traditional “French” model, creation of a common culture in the sense of a “melting pot” as the traditional “American” model, multiculturalism as the “Canadian” model, and separation as the traditional “German” or “Swiss” guest-worker model. Kälin (2003), p. 273.

53. Here assimilation is based on the expected outcome of full citizenship and the sharing of common civic values with the native population. This is a one-sided process of adaptation in which migrants adopt the language, norms and behaviour of the receiving society. Segregation does not expect migrants to assimilate into the culture of the host society, and is generally ap- plied to temporary migrants. The temporary nature of the immigration system leads to grant- ing migrants limited social rights. Integration, also known as a “melting pot”, is a two-way process of mutual accommodation between migrants and the receiving society in which these two groups accept and contribute to a common culture. People of different cultures learn from each other’s culture, while each individual or cultural group retains some sense of cultural heritage and diversity. Multiculturalism recognises cultural plurality in modern societies and tries to regulate this through principles of equality. Migrants remain distinguishable from the majority population through their language, culture and social behaviour without jeopardising the national identity. Multiculturalism privileges a culture of tolerance for different ways of life. IOM (2005), p. 322.

54. This model has been put forward in Castles (2005), pp. 286–288.

the 1970s in Western immigration countries. The result was the introduction of of- ficial policies of multiculturalism that implied abandonment of the myth of homog- enous and monocultural nation-states and entailed the recognition of immigrants’

rights to cultural maintenance and community formation. These policies were also linked to social equality and protection from discrimination. Multicultural models were first developed in Canada and Australia, and subsequently also in other states in the Western world.⁵⁵ Although the use of the term “multiculturalism” declined in popularity in the 1990s, the notion of multicultural and multiethnic societies has become firmly entrenched in Western countries.⁵⁶ Theories of multiculturalism are (still) visible in the contemporary discussions on migrant settlements and integra- tion in the area of immigration and ethnic studies.⁵⁷ It is also important to be aware that, much like various other concepts used in the area, multiculturalism has been given different definitions.⁵⁸ It is noteworthy that multiculturalism has not neces- sarily been distanced from policies of controlling difference within the nation-state framework, because it does not question the territorial principle and implicitly as- sumes that migration will lead to permanent settlement and the birth of second and subsequent generations who are both citizens and nationals. Thus, multiculturalism maintains the idea of a person primarily belonging to one society and being loyal to just one nation-state.⁵⁹

While the issue of integration (in its various manifestations) is both a reality of and a challenge for every immigrant-receiving society, it is not limited to the phe- nomenon of migration. It has been pointed out, that, in general, culturally diverse societies and even societies that are strongly stratified along class lines constantly

55. Castles points out that many sociologists (especially in the US) have viewed assimilation as an inevitable and necessary process for permanent migrants, and that assimilation leads logically to incorporation of immigrants and their descendants as new citizens. “Guest- worker” or temporary labour recruitment systems employed by, for example, Germany in the post-1945 era are labelled as differential exclusion. Multiculturalism as a state policy was introduced in Canada and Australia in the 1970s. Ibid., pp. 286–288.

56. Castles also suggests that multiculturalism is primarily a phenomenon and concept in Western society. Ibid., p. 288.

57. See also Martikainen (2005), pp. 1–2.

58. Charles Taylor and Will Kymlicka from Canada and Bhikhu Parekh from Britain are con- sidered to be among the key theorists associated with multiculturalism. It has been pointed out that the theories developed by these authors also necessarily reflect the realities of their respective societies. Kivisto (2005b), pp. 20–21. See also Kivisto (2005c), pp. 314–315.

For a somewhat different content for multiculturalism, including its being viewed slightly differently in the US context than, for example, in Canada, see Castles (2005), p. 288. For dif- fering definitions of multiculturalism, see also Alexander (2005), pp. 320–322. Alexander sug- gests that multiculturalism should be considered as a new and more democratic mode of civil integration. Ibid., p. 322. See also the remarks on similarities between multicultural theories and assimilation in the USA infra. Some scholars have suggested that multiculturalism is a new term being used to refer to cultural pluralism. Glazer (2005), p. 113.

59. Castles (2005), p. 288. See also the remarks on transnationalism infra in chapter 5.2.2.

face issues relating to integration that are not necessarily very different from the problems of societies that have to deal with culturally different or socially margin- alised immigrants.⁶⁰ Furthermore, the issue of integration is also relevant in the case of older (traditional) minorities and indigenous peoples. Despite this, the issue has been clearly less intensively discussed in the case of these groups than in that of immigrants. And although express remarks can be found on integration and as- similation in the works on minorities and indigenous peoples, the concept of inte- gration does not usually appear among the key words or concepts in contemporary publications in the area.⁶¹ In recent years in Europe the issue of integration has been brought up particularly in connection with the Roma.

In sum, the concept of integration (as well as its neighbouring concepts) is used in varying contexts and differing meanings have been attached to it. Furthermore, what integration and the concepts often linked to it mean in practice, i.e. what their actual content is, is often not so easy to ascertain. The divergent use of the very same term adds to the confusion.⁶² The area is further complicated by the very different usage on different sides of the Atlantic. For instance, whilst the term “assimilation”

has become unpopular in both Europe and many international contexts, in the USA it has been, and still is, widely used in theories relating to immigrant incorpora- tion.⁶³ For historical reasons, that is, the country’s longer history as an immigrant- receiving country, the development of these theories has a much longer history in the US than in Europe.⁶⁴ It has also been pointed out that the contested concept of assimilation does not “travel well” and is in fact often lost in translation.⁶⁵ Ad- ditionally, the concept of assimilation has been given a variety of meanings in the US, where there is also considerable confusion as to its content.⁶⁶ The concept of

60. Kälin (2003), p. 271.

61. Regarding writings on minorities, see e.g. the indexes in Thornberry (1991) and Weller (2005).

62. That divergent usage of the same term, in this case “assimilation”, contributes to confusion has been discussed in a number of articles in Incorporating Diversity. Rethinking Assimilation in a Multicultural Age, Kivisto (ed.), 2005.

63. Kivisto (2005b), p. 3.

64. Robert E. Park has been one of the key scholars in formulating assimilation theories in the US. Ibid., p. 7. Park has treated assimilation as a process pertaining to all ethnic groups, but has considered particularly the incorporation of Afro-Americans in the US. See Park (2005).

It has also been pointed out that, in the US, assimilation came to be equated with Ameri- canisation back when the influx of immigrants from Eastern Europe and the Mediterranean countries began, who were suspected of being inferior stock and less easily assimilable than immigrants from northwestern Europe. Dictionary of Race and Ethnic Relations (1996), p.

43. See also Yinger (2005), p. 174.

65. Kivisto (2005b), p. 4.

66. Ibid., pp. 3 and 4. On the confusing and often contradictory uses of “assimilation” in the USA, see also Morawska (2005), p. 129, and Yinger (2005), p. 175.