Note 13 of the Verification Committee's list of observations to modify the course of the Iraqi initiative to lift Iraq’s suspension of Iraq's membership in the 2017 International Initiative for Transparency in Extractive Industries indicates that "the number of CSOs representatives in the Stakeholder Council is unclear." While the national secretariat's answer was that the number is (8), which refers to NGOs in general, while the actual number of representatives of civil society CSOs is 3, in the absence of the fourth representative from the provinces of Iraqi Kurdistan due to the failure of the elections for 2016 in Erbil, this is the number currently in force according to the rules of procedure adopted for 2013.

"However, there has been a delay in nominating representatives of the private sector, media and academics, due to delays in the relevant authorities or because of the resignation of candidates despite official invitations," the Secretariat adds. They are all NGOs and cannot be counted on the basis of being representatives of CSOs, as they have their own independent regulatory and trade union laws and are not covered by Law 12 of 2010.

In this context, we note that:

1. 1. There is a clear confusion between the concepts of NGOs and CSOs.

2. There is a clear and specific period for the nomination and election of representatives of CSOs to the Board of Trustees.

3.The rules of procedure of the Iraqi Initiative do not indicate the existence of such nominations and elections for private sector, media and academic representatives, namely NGOs, with no determination of the duration and mandate of these members and the context of their change in the Board of Trustees, and this is the 14th observation in the verification committee's list of observations, noting "the lack of procedures for nominating and changing other members of the Stakeholder Council, including their terms of office", and no amendment to the articles of the II's rules on this important topic.

4. If the private sector has a candidate from the Iraqi Federation of Industries and the media have a candidate from the Journalists Syndicate, we do not know here how the National Secretariat of the Initiative will get an academic candidate and who ever nominated it. If it’s meant that these are research centers or associations for academics, then they fall under the CSOs concept and will be subject to Law 12 of 2010.