59. Similar criticisms made by international organisations (including the UNHCR),36 representatives of national governments 37 and domestic courts38 demonstrated that INTERPOL should take seriously the risks to its reputation. Further, the results of a survey of EU Member States conducted by the European Commission highlighted concerns about the reliability of Red Notices, with half of the responding EU Member States stating that they had encountered unlawful Red Notices and the majority confirming that they do not treat a Red Notice as a valid reason to arrest someone without further checks.39 This arose in the context of other threats to INTERPOL: credibility. The decision to conclude INTERPOL’s profitable relationship with FIFA during 2015, following worldwide coverage of FIFA’s corruption scandal, was explained by the need to protect INTERPOL from “taking decisions that pose high reputational risk”,40 emphasising the new focus on building trust. 60. It is clear that while INTERPOL concluded for itself that it should prioritise efforts to protect its immunity and improve its credibility, The pressure imposed through a combination of media scrutiny and examination by international and regional bodies has almost certainly played a role in leading INTERPOL to conclude that it should prioritise its immunity and credibility through a series of reforms. Media coverage of the misuse of INTERPOL’s systems has certainly increased since 2013, with major outlets including The Washington Post, The New York Times, The Economist, Deutsche Welle, El Pais, and Al Jazeera being critical in their assessments. Vincent Cochetel, Deputy Director of the division of International Protection Services, UNHCR stated in 2008, while discussing issues which undermined international protection, that “UNHCR is also confronted [with] situations whereby refugees… when travelling outside their country of asylum .. are apprehended or detained, due to politically-motivated requests made by their countries of origin which are abusing of Interpol’s ‘red notice system’. Such persons are often left without access to due process of law, and may be at risk of refoulement or find themselves in ‘limbo’ if they are unable to return to their country of asylum”. Available at: http://www.refworld.org/pdfid/4794c7ff2.pdf. 37 In June 2013, following an embarrassing situation in which the Australian authorities relied upon information in an INTERPOL Red Notice which was later found to be incorrect, the Australian Immigration Minister, Brendan O’Connor, commented that the Australian police must examine the veracity of Red Notices because quite often the claims within them “are found to be wrong”. (David Wroe, ‘Interpol notices ‘often wrong’: Minster Contradicts AFP’, The Age, (17 June 2013) http://www.theage.com.au/federal-politics/political-news/interpol-notices-often-wrong-minister-contradicts-afp-20130617-2oe86.html). In 2011, the Polish Ministry of the Interior called for reforms to INTERPOL following the arrest of Ales Michalevic on the basis of a Red Notice (Radio Poland, ‘Poland wants changes to Interpol arrest system’ (15 December 2011) Available at: http://www.thenews.pl/1/10/Artykul/80561,Poland-wants-changes-to-Interpol-arrest-system) 38 See Rihan v. Minister of Citizenship and Immigration [2010] FC 123, in which a Canadian Federal Court judge warned against treating a Red Notice as conclusive for the purpose of excluding a person from refugee status pursuant to Article 1F(b) of the 1951 Convention relating to the Status of Refugees due to doubts casted on its content . See also Leke Prendi aka Aleks Kola v Albania [2015] EWHC 1809 (Admin), in which the High Court clarified the evidential test relating to the admission of evidence in extradition proceedings and raised questions as to the reliability of Red Notices in this context. 39 Parliamentary Assembly of the Council of Europe, Committee on Legal Affairs and Human Rights, ‘Abusive use of the Interpol System: the need for more stringent legal safeguards’, Report No. 14277 (29 March 2017) (‘PACE Report’) adopted by Resolution 2161 (2017) (26 April 2017), para. 57 40 Stock (n 28) 36 26 d) Political and Media Pressure