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10.21.2.2 No Punishment for Making Complaints. Even if the petitions andcomplaints are recognized to be unfounded, they may not occasion any punishment. 334 In anyevent, as in the case of POWs, it could be contrary to internees’ interests to abuse this right bymaking groundless complaints because complaints that are justified might not, as a result,receive the appropriate attention. 33510.21.3 Periodic Reports by the Internee Committees. Periodic reports on the situation inplaces of internment and as to the needs of the internees may be sent by the Internee Committeesto the representatives of the Protecting Powers. 336 Internee Committees have discretion abouthow and when to submit their reports. 337 The Detaining Power may subject these reports tosecurity review and censorship to ensure that these reports are not misused. 33810.22 INTERNEE COMMITTEES10.22.1 Election of Internee Committees. In every place of internment, the interneesshall freely elect, by secret ballot every six months, the members of a Committee empowered torepresent them before the Detaining and the Protecting Powers, the ICRC, and any otherorganization that may assist them. 339 The members of the Committee shall be eligible for reelection.34010.22.1.1 Approval of Internee Committee Members by the Detaining Authorities.Internees so elected shall enter upon their duties after their election has been approved by thedetaining authorities. 341 The reasons for any refusals or dismissals shall be communicated to theProtecting Powers concerned. 342334 GC art. 101 (“Such petitions and complaints shall be transmitted forthwith and without alteration, and even if thelatter are recognized to be unfounded, they may not occasion any punishment.”).335 Compare § 9.23.2.2 (No Punishment for Making Complaints).336 GC art. 101 (“Periodic reports on the situation in places of internment and as to the needs of the internees, may besent by the Internee Committees to the representatives of the Protecting Powers.”).337 GC COMMENTARY 436 (“Some of the Government Experts who met in 1947 had envisaged making it obligatoryto transmit periodically to the Protecting Power reports drafted on a model form. This opinion did not prevail in thesense that it was given mandatory form; the idea of periodical reports was retained, but the Convention leaves it tothe Internee Committees to submit their reports when and how they think fit.”).338 Refer to § 10.23.6 (Censorship and Security Review of Internee Correspondence and Shipments).339 GC art. 102 (“In every place of internment, the internees shall freely elect by secret ballot every six months, themembers of a Committee empowered to represent them before the Detaining and the Protecting Powers, theInternational Committee of the Red Cross and any other organization which may assist them.”).340 GC art. 102 (“The members of the Committee shall be eligible for re-election.”).341 GC art. 102 (“Internees so elected shall enter upon their duties after their election has been approved by thedetaining authorities.”).342 GC art. 102 (“The reasons for any refusals or dismissals shall be communicated to the Protecting Powersconcerned.”).692

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