Human Rights of Armed Forces Personnel Fonction Militaire, or CSFM) provided for participation in discussions concerning conditions of service.264 However, the General Statute of the Military was changed in July 2015, based on the judgments of the European Court of Human Rights (Matelly v. France and ADEFDROMIL v. France, see Box 7.3), so that French military personnel are now allowed to join national military professional associations that can have a seat in the CSFM, under certain conditions. Created in 1990, the CSFM advises on questions related to the conditions of service and must be consulted if legislation or regulations related to these conditions are proposed. The CSFM may deal with various topics, including career development, transition to civilian life, welfare in the Armed Forces, pension reform, housing and the conditions of international operations. An item may be put on the CSFM’s agenda by a majority of the members. Seven councils (known as CFM) have been created to represent the army, the air force, the navy, the military constabulary, the medical corps, the procurement agency and the energy agency, respectively. The members of the CSFM are elected for four-year terms by and from among the members of the seven CFM. The councils have two functions – to study any question related to the conditions of service or the organization of work in the forces, and to represent the viewpoint of forces personnel on the topics submitted to the CSFM. A similar approach is followed in Italy.265 As the name suggests, non-autonomous arrangements may be perceived as having less credibility or legitimacy in representing the interests of armed forces members, as they are not created by the members themselves but are imposed from above by the government. While it may be easier for the armed forces to consult with such bodies, the absence of democratic accountability to those whose interests they represent can also undermine their authority to speak on behalf of members of the armed forces. The third approach is for there to be an authorized but autonomous military association (professional association or trade union). This approach provides no legal restrictions on service personnel joining military associations. Some associations of this kind are longstanding, such as those in Belgium, the Netherlands (the first such association was formed in the late 19th century) and Sweden. In other states, such as Bulgaria, Hungary, Poland and Romania, such associations have come about due to recent legal or constitutional changes. 264 See: “Conseil Supérieur de la Fonction Militaire [Higher Military Council]”, the Ministry of the Armed Forces of France, http://www.defense.gouv.fr/csfm. 265 120 Code of Military Order of Italy (Law n.210/66), Art. 1475: Italian response to ODIHR-DCAF 2018 questionnaire. See also: V. S. Nesterov and A. D. Pruefert, Military Unionism: The Establishment of Professional Organisations/Trade Unions of Servicemen and their Present Position (Moscow: Ves Mir, 2006), pp. 119-121.