5 gaps in MNHRC’s draft Strategic Plan

MNHRC’s decision to openly consult with civil society on its Draft Strategic Plan 2020-2024 demonstrates a willingness to conduct a real, substantive and open consultative process. FEM has reviewed the Draft on the basis of international standards and past experiences, and makes 5 positive recommendations to improve it.

1. “SWOT analysis” does not include weaknesses identified by UN

As a GANHRI member, the MNHRC has committed to the Paris Principles and therefore implicitly to aim to increase its current GANHRI “B” grade to an “A”. GANHRI has already explained what the MNHRC needs to do in order to get an “A” grade. In particular, GANHRI recommended some significant changes to the MNHRC to safeguard its independence from the government.

However, the Draft SWOT Analysis does not refer to the MNHRC’s weaknesses highlighted in the GANHRI report. Instead, it is mostly concerned with the internal operational workings of the MNHRC. These are important, but far less important than the extent to which MNHRC is delivering its institutional mandate. Additionally, weaknesses are not examined in enough detail to devise a strategic solution. For example, is it difficult to recruit and retain well-qualified staff because of low salaries, work culture, or its image among human rights professionals?

A robust analysis of the MNHRC’s external threats and opportunities is vitally important for strategic development but is almost entirely absent from the Draft.


  • Conduct an additional, open, and solutions-orientated SWOT analysis, but this time including human rights professionals, with a focus upon 1) unpacking weaknesses to understand why they exist and how they can be solved, and 2) identifying external opportunities and threats to delivering the MNHRC’s institutional mandate.

2. “Priority Issues” lack civil and political rights violations

In strategic design, a SWOT analysis is usually accompanied by a PESTLE (political, economic, social, technological, legal, environmental) analysis which would better identify “Priority Issues” that the MNHRC should be concerned with during the strategic period.

However, the Draft has no PESTLE analysis and the Priority Issues list omits several critical human rights issues in Myanmar that would be quickly identified in a PESTLE, notably relating to violations of civil and political rights. In particular, a PESTLE analysis of Myanmar would unquestionably identify the comparatively high number of violations of the rights to freedom of expression, information, assembly, association, privacy, and participation in political life. Violations of these rights have been examined in detail in numerous reports, including by FEM. By failing to include these, the MNHRC may open itself up to civil society allegations of bias.

The Priority Issues are also often too vaguely described for strategic development. For example, “torture”is included as just a single word. In order be useful, the Draft Strategic Plan needs to take a risk and clearly identify and explain each issue so that a workable plan can be developed in response.


  • Conduct an additional and open PESTLE analysis including human rights professionals, with a focus upon 1) analysing and adding violations of civil and political rights to the Priority Issues list, and 2) unpacking each Priority Issue so that they are clearly defined.

3. “Goals” need to include holding perpetrators accountable

Goals are best described as results that an organisation is able to achieve. This requires goals to be realistic and within the MNHRC’s ability to deliver. If goals are unrealistic and not deliverable then MNHRC’s performance – and the performance of its staff and commissioners – cannot be fairly judged. Without effective measurement of performance, stakeholders do not know whether MNHRC is being run in an effective manner, and do not know where to make improvements.

Some of the MNHRC’s Goals are not realistically within the organisation’s direct influence and are therefore unachievable. For example, Goal 3 cannot be directly achieved by the MNHRC because the MNHRC does not realistically have a direct influence over the many human rights violations occurring in Myanmar. Although unrealistic, Goal 3 is important because it is the only goal which suggests the MNHRC’s duty to intervene to try to stop human rights violations – including where there is no complainant. The MNHRC’s other Goals are all positive duties (e.g. to educate) which are comparatively easy to deliver because they do not require the MNHRC to take a risk and confront abusive actors.


  • Revise the Goals with human rights professionals, to ensure that the MNHRC can directly achieve them. Ensure that any revision places a duty on the MNHRC to intervene to try to stop human rights violations. For example, Goal 3 could be amended to state “hold human rights violators to account”.

4. MNHRC “Objectives” need strengthening

Objective 1.1.1:It is admirable that the MNHRC wants to amend the MNHRC Law in order to fully comply with the Paris Principles. However, there are many stakeholders in Myanmar that also want to amend the MNHRC Law, particularly human rights professionals. The MNHRC should include these stakeholders within its Target Groups and Activities. In particular, the MNHRC should view these stakeholders as critical allies in amending the Law, and work with them to develop plans, share intelligence, and conduct advocacy. The MNHRC should ensure that advocacy recommendations reflect the views and needs of those stakeholders too.

Objective 1.1.2:Increasing accessibility is undoubtedly important to improving the MNHRC. However, accessibility should not just be measured in terms of the number of offices, visits, or meetings, because these are measurements of the MNHRC’s workload and not really measurements of how accessible the MNHRC is to the public. Accessibility should instead be measured on how stakeholders interact with the MNHRC. For example, a good measure of accessibility is the number of people who approach the MNHRC and register a complaint or ask for support.

Objective 2.1: Raising awareness of human rights is important in Myanmar. However, the MNHRC has only limited capacity, budget, and staffing. Therefore, the MNHRC would achieve far greater long-term impact if it focused on encouraging other, much larger and more influential government actors, to raise awareness of human rights, rather than the MNHRC doing it itself. For example, encouraging the Ministry of Education to include human rights within the curriculum would reach millions of school children, rather than just the hundreds reached in MNHRC-organised competitions or workshops.

Objective 3.1:Effective complaints mechanisms ensure that violations are more likely to be challenged by the MNHRC. However, it is not sufficient to have a strategic aim to “review”and “develop a plan”. The strategic aim should be to significantly increase the number of complaints that are resolved to the satisfaction of the complainant. Reviewing the current systems and developing a plan are the first step in this process, but they are not the final step.

Objective 3.2:Myanmar desperately needs more authoritative commentary on all legislation going through parliament in order to ensure it is in line with international human rights standards. However, this objective lacks robust detail compared to others. The MNHRC should have a team of human rights professionals – lawyers trained in human rights standards – who are empowered to do high-quality research and analysis, and the MNHRC should seek outside support where it lacks expertise. The MNHRC should have a mechanism to monitor legislation and to pull together civil society stakeholders. The MNHRC should publish technical documents, and these should be aimed at civil society as well as MPs.


  • Revise1.1 to include allied stakeholders in the development and implementation of all activities.
  • Revise 1.1.2 to include activities that promote complaints, and include indicators that measure how many people register a complaint or ask for support.
  • Revise 2.1 to reduce the number of activities to focus on those that are the most likely to have a snowball effect on awareness, particularly engaging with government departments responsibly for education, state media, and security services.
  • Revise 3.1 to significantly increase the number of complaints that are successfully handled.
  • Revise 3.2 to increase activities to build legal expertise, develop legal analysis, monitor legislation, and engage with civil society and MPs to build capacity and awareness.

5. Missing contents

Any strategic plan should include details on how implementation will be measured, and how changes can be made to improve implementation. Multi-year strategies should also include a timeline of what will be prioritised and implemented for each year that the plan covers. In particular, some strategic elements will be consequential (i.e. one element is implemented first and a second implemented on top of the first). Unusually, the Draft Strategic Plan does not include any financial details relating to the MNHRC’s budget or financial management.


  • Add a section explaining the MNHRC’s plans for monitoring, evaluating and learning throughout the strategic cycle.
  • Add a section (or further detail in the tables) explaining the timetable for implementation.
  • Consider including a strategic plan covering the MNHRC’s budget and financial management.