To the Commissioner for the Protection of Equality
CC: To the Ministry of Labor, Employment, Veterans and Social Affairs,
Coordinating Body for Gender Equality
Dear Mrs. Janković,
The Autonomous Women's Center addresses you regarding the opinion you gave on July 22, 2021 on the Proposal of an Action Plan for the Implementation of the Strategy for Preventing and Combating Gender-Based Violence against Women and Domestic Violence.  Although we have not seen the text of this document, according to your comments, we get the impression that it is flawless, and that its only shortcoming (not counting the terminological inconsistency with which we agree) is that "there is no justified reason that in the activities provided for in the Proposal of the Action Plan, single out the so-called women's organizations of civil society."
We were surprised and worried by your statements that:
- Determination by gender does not make a civil society organization competent to carry out activities related to the issue of gender-based violence.
- Even in situations where it is recommended that a woman provide support to a victim of gender-based violence, it is not necessary or justified for her to be a member of a so-called women's organizations.
Gender determination makes a civil society organization dedicated to women's rights competent for specific activities that are the subject of a specific strategy and accompanying action plan. The "privileging" of these organizations can also be considered a special (affirmative) measure introduced to achieve the protection and progress of a (social) group that is in an unequal position. In other words, we consider it justified to give preference to organizations formed by women to support women, because the problem of male violence against women was recognized, named and sanctioned precisely because women self-organized with this goal in mind. It was not mixed groups, nor groups for general victim support, that were able to recognize and name the problem, and that is not accidental. A mixed structure does not necessarily provide a safe space in which women can share the experience of the violence they have experienced without fear, in which they will receive understanding and support. It is clear that even the same-sex structure of members does not necessarily provide that kind of safe space, but we remind you that gender orientation is not the only thing that makes women's civil society organizations competent, but also long-term expertise and commitment to feminist policies and principles of work that are based on for the purpose of abolishing men's violence against women. In addition, international treaties, and especially the Council of Europe Convention on preventing and combating violence against women and domestic violence, with which the mentioned Strategy and Action Plan against violence are harmonized, do not deny the importance of women's organizations and specialized women's support, but, like other treaties of this type, recognizes the importance of support provided by women for women  and thus honors women's organizations for their civilizational contribution to the advancement of human rights.
Gender-based violence, as you call it in the given opinion, is a recent term - and women's organizations, revealing the problem, talked about men's violence against women. The imbalance of physical, political, social and economic power between the sexes was the focus of this term. We believe that you will agree with the fact that the equalization of power between the sexes has not (yet) occurred, but that the term was first replaced by the term "gender-based violence against women" (the term used in the Council of Europe Convention), and then "gender-based violence". Women, who are predominantly victims of male violence and make up over 50% of the population, have become invisible through this terminological reduction, which takes us back many decades, to the very beginning of the feminist struggle for the visibility of male violence against women - the most widespread form of discrimination against women in society.
We agree that gender roles operationalize inequality between men and women, but gender roles are assigned based on gender, not the other way around. Sex (biological determinant) of a person is the basis for assigning gender (social construct). Society perceives a person of female and male gender in a different way, assigning them privileges and responsibilities unequally. Both genders will form their self-image by reflecting this perception (e.g.: if society perceives a woman as the weaker sex, she will most often integrate this self-image to a greater or lesser extent). Thus, both sexes acquire a specific (and often different) life experience, integrating specific (and often different) self-images. On the basis of a specific common experience (enlightened), women will usually better understand the experience of another woman, be able to provide her with more adequate support, interpret the problem in the way the one affected by this problem perceives it. This is precisely why it is important to continue naming male violence against women and that services to women who have survived violence be provided by (assertive) women, as well as that preference for dealing with policies and practices in this area be given to women's organizations.
It is true that victims of domestic violence can also be men, as you stated in your opinion. We also believe that for a society that strives for gender equality, the existence of various civil society organizations that specialize in the prevention of male violence against women and men (for example, organizations that include boys and young men in educational activities) is important, because violence against men is also predominantly committed by men .
However, in view of all the above, we believe that it is necessary for the Commissioner for the Protection of Equality not only to preserve space for the specific action of women's organizations when it comes to men's violence against women (which prevails even within the category of domestic violence), but also to actively provide understanding and support for their work - primarily in the area of providing direct services to women, but also in other areas aimed at preventing and protecting women from violence.
The attitudes you stated are particularly dangerous because they can be interpreted as diminishing the importance of women's organizations at a time when the need for them in Serbia is growing, i.e. when the number of calls made to SOS phones of women's organizations is increasing, and the number of reports to the police is decreasing , which is partly the consequence of the pandemic and the slowness of the system to respond to the needs in changed working conditions. Downplaying the importance of women's groups also favors the continuation of attacks by right-wing groups and individuals on women's organizations and defenders of women's rights, which we consider particularly worrying.
Finally, as long as the Index of Gender Equality in the Republic of Serbia  shows slow and hesitant progress, we see no reason not to oppose the official policy of appointing institutions of the Republic of Serbia exclusively in the male gender, instead of giving in to it.
Updated: February 9th, 2022
The response of the Commissioner for the Protection of Equality to the address of the AWC is available HERE .
 The opinion is available via the following link: http://ravnopravnost.gov.rs/misljenje-na-predlog-akcionog-plana-za-period-od-2021-do-2023-godine-za-sprovodjenje-strategije-za-sprecavanje-i-borbu-protiv-rodno-zasnovanog-nasilja-prema-zenama-i-nasilja-u-porodici-za-period-od/
 Article 14 of the Law on Prohibition of Discrimination.
 Istanbul Convention, Article 22 Specialized Support Services, Paragraph 2. Document available via link: https://rm.coe.int/168008482e
 When it comes to male victims of domestic violence, the perpetrators of violence are also predominantly male, in at least 4233 cases (72.2%), as well as women in 1474 cases, Ninth report on independent monitoring of the implementation of the Law on Prevention of Domestic Violence in Serbia for the period January - December 2020, Autonomous Women's Center, June 2021. More information available via the link: https://www.womenngo.org.rs/images/resurs-centar/AWC_Ninth_Report_on_Independent_Monitoring_2020.pdf
 For more information see the infographic available via the following link: https://www.womenngo.org.rs/images/resurs-centar/INFOGRAPHIC_Implementation_of_the_Law_on_Prevention_of_Domestic%20Violence_2020.pdf
 Source: http://socijalnoukljucivanje.gov.rs/wp-content/uploads/2021/10/Indeks_rodne_ravnopravnosti_u_RS_2021.pdf