2 PROCEDURE 1. The complaint lodged by the international non-governmental organisation, Marangopoulos Foundation for Human Rights (“MFHR”), maintains that Greece has failed to comply with Article 11 of the European Social Charter (the Charter) because in the main areas where lignite is mined the state has not taken sufficient account of the environmental effects or developed an appropriate strategy to prevent and combat public health risks. The MFHR also alleges that there is a violations of Articles 2§4 and 3 of the Charter because there is no legislation to ensure the security and safety of persons working in lignite mines and the latter do not benefit from reduced working hours or additional holidays. 2. Article 2§4 of the Charter reads as follows : Article 2 – The right to just conditions of work Part I "All workers have the right to just conditions of work." Part II: "With a view to ensuring the effective exercise of the right to just conditions of work, the Contracting Parties undertake: […] 4. to provide for additional paid holidays or reduced working hours for workers engaged in dangerous or unhealthy occupations as prescribed"; 3. Articles 3§§1 and 2 of the Charter read as follows : Article 3 – The right to safe and healthy working conditions Part I: "All workers have the right to safe and healthy working conditions." Part II: "With a view to ensuring the effective exercise of the right to safe and healthy working conditions, the Contracting Parties undertake: 1. to issue safety and health regulations; 2. to provide for the enforcement of such regulations by measures of supervision". 4. Article 11 of the Charter reads as follows : Article 11 – The right to protection of health Part I "Everyone has the right to benefit from any measures enabling him to enjoy the highest possible standard of health attainable." Part II: "With a view to ensuring the effective exercise of the right to protection of health, the Parties undertake, either directly or in cooperation with public or private organisations, to take appropriate measures designed inter alia: 1. to remove as far as possible the causes of ill-health; 2. to provide advisory and educational facilities for the promotion of health and the encouragement of individual responsibility in matters of health; 3. to prevent as far as possible epidemic, endemic and other diseases."