The General Equal Treatment Act (AGG) of 2006 partly covers the requirements of the EU Directives on Equal Treatment. By accompanying complaints of discrimination and their judicial interpretation, the BUG determined that the existing AGG also contains provisions which should be strengthened. In addition, the AGG contains rule-exceptions that do not appear to be effective.
Examples of these include a lack of status in court or a right to bring an action before an association, the comparatively weak mandate of the Federal Anti-Discrimination Agency (ADS), and the granting of legal protection against structural discrimination.
Following a thorough analysis, the BUG has drawn up a comprehensive paper, that lists the bodies in the AGG that still need to be supplemented or modified in addition to offering new suggestions.
You can read the paper here.
§ 13 AGG obliges employers to set up an internal complaints office to which employees can turn if they feel discriminated against on grounds of their ethnic origin, gender, religion or belief, disability, age or sexual identity. However, such a position has rarely been created, especially in private enterprises. BUG has drawn up a comprehensive concept (3rd edition) for setting up internal complaints offices. The concept is intended to serve as a handbook for companies and administrations on how this office could be meaningfully organized on a personnel and organizational level and how it could be integrated into existing complaint structures. The concept consists of a modular system which provides information - depending on the size and location of the company - on how the internal complaints office can be set up. It also contains a checklist for setting up the internal complaints office. You can order a manual of guidelines for dealing with complaints for a nominal fee from BUG (message to: firstname.lastname@example.org). You can find excerpts from this manual here.
You will find a German version of the 3rd edition of the concept here.
Here you can read the 2nd edition in English.
Regarding the exercise of police activities, criticism of the actions of the Federal Police has been repeatedly voiced. Non-suspicious checks on persons are seen as arbitrary, unjustified, or disproportionate - especially if persons are categorized as foreign and thus illegal. This form of person-checking based on phenotypic characteristics is called 'racial profiling' and in recent years has been the subject of frequent legal action against the Federal Police. So far, such complaints can only be submitted to the police themselves. In other European countries, however, there are independent police complaint offices which have the mandate to examine and process complaints.
In cooperation with other human rights organizations, the BUG has developed a comprehensive concept (only available in German) regarding the structure, powers, and activities of an independent complaints office for the police, as it should be set up in Germany.
The German population has grown increasingly diverse in the past decades. People from all over the world come to Germany to study, get married, or find employment. So far, this diversity has only been partially documented and analyzed.
If there is no statistical data available, this becomes a problem as soon as politics are supposed to respond to the needs of the German population regarding employment, education, and measures against discrimination. As a result the needs of specific groups cannot be dealt with.
Looking at the German historical context, the collection of such data is very controversial and occasionally met with skepticism from those affected.
Regarding qualitative and quantitative are data necessary for strengthening equal treatment against minority groups or people with migration background, recognizing issues, and implementing the appropriate actions.
The BUG has developed an expertise about this topic, where the principles for the collection of data are described. This expertise is also available in English.