professions, or by unions in areas with the same or similar economic activities or geographical locations.  A union confederation or a coalition of union federations or union alliance is a professional organization of workers that is established jointly and voluntarily by union federations.  A national council of unions, which comprises of all union confederation(s), all coalitions of union federation(s) or union alliances, is to be the only legally unified representation of the entire union organization.  An employer federation refers to a professional organization, which is established jointly and voluntarily by employer associations.  Shutting down the operation completely refers to a closing of an enterprise or establishment according to the law and regulations in force. Comments: Contrary to the aims of professional organizations as set out above “to cooperate with one another to carry out activities or to develop their own procedural rules,” the fundamental purpose of the right to form and join trade unions of one’s choice is to promote and protect one’s economic and social interests,11 as recalled by the SRFAA.12 This is affirmed in ILO Convention No. 87, whereby organizations are created “for furthering and defending the interests of workers and employers”. Cooperation and the development of internal rules are means by which workers and employers seek to achieve the ultimate aim of furthering their interests. OHCHR suggests the following reformulation of the first bullet point: A professional organization refers to a voluntarily established group of workers or employers through which workers and employers promote and defend their respective interests. Toward this end, professional organizations develop their own procedural rules, undertake activities and negotiate in regard to their demands. Professional organizations may cooperate with one another to achieve specific professional objectives or goals. By virtue of this law, a professional organization of workers is called a union, whereas a professional organization of employers is called an association of employers. OHCHR further recommends removing the second to last bullet point on a national council of unions, as the rights and responsibilities of a national council of unions are not developed in the draft law. The lack of clarity about the implications of being “the only legally unified representation of the entire union organization” could be interpreted as an imposition on trade unions, which would be contrary to ILO Convention No. 87. CHAPTER 2 Fundamental rights to establish and to join a union or employer association Article 5: All workers and employers have, without any distinction whatsoever, the rights to form a union or an employer association of their own choice for the exclusive purpose of study, research, training, promotion of interests, and protection                                                              11 12 ICESCR, article 8, para. 1. A/HRC/20/27, para. 53. 7