In Jones and others v. United Kingdom (2014), the European Court of Human Rights (ECtHR) ruled that granting immunity from jurisdiction to State officials in civil proceedings with respect to torture was not a violation of Article 6 ECHR. This is an unfortunate decision, as its application will often result in an accountability vacuum, as victims of torture may not have reasonable access to remedies in the State where they were tortured. Only bystander States, or their State of nationality could then offer relief by offering a forum. A proper avenue for such States is to make the exercise of jurisdiction and the conferral of immunity dependent on whether or not the territorial State offers an adequate forum for dispute-settlement. By further developing these principles, the notion that, under international law, persons are individually accountable for international crimes and should not be allowed to hide behind the State on whose behalf they act, could be finally realised.
{"title":"Jones v. United Kingdom: The European Court of Human Rights Restricts Individual Accountability for Torture","authors":"Cedric Ryngaert","doi":"10.5334/UJIEL.CN","DOIUrl":"https://doi.org/10.5334/UJIEL.CN","url":null,"abstract":"In Jones and others v. United Kingdom (2014), the European Court of Human Rights (ECtHR) ruled that granting immunity from jurisdiction to State officials in civil proceedings with respect to torture was not a violation of Article 6 ECHR. This is an unfortunate decision, as its application will often result in an accountability vacuum, as victims of torture may not have reasonable access to remedies in the State where they were tortured. Only bystander States, or their State of nationality could then offer relief by offering a forum. A proper avenue for such States is to make the exercise of jurisdiction and the conferral of immunity dependent on whether or not the territorial State offers an adequate forum for dispute-settlement. By further developing these principles, the notion that, under international law, persons are individually accountable for international crimes and should not be allowed to hide behind the State on whose behalf they act, could be finally realised.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-08-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726651","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The Global Compact (UNGC) represents the world’s largest corporate citizenship initiative today. Created under the auspices of the United Nations (UN) to encourage companies around the world to adopt sustainable and socially responsible policies, the UNGC brings together businesses, UN agencies and labour groups in search of compromises. In a phone interview with the Journal’s team, Ursula Wynhoven, General Counsel and Head of the UN Global Compact, shared her views on current issues and challenges of the field. Before joining the UN, she was engaged with the Organisation for Economic Co-operation and Development (OECD) on the development of the OECD Guidelines for Multinational Enterprises (MNEs). Ursula Wynhoven has also worked as a lawyer in governmental human rights agencies and private practices in the United Kingdom, the United States and Australia, and is an adjunct professor at the University of Reykjavik’s School of Law in human rights and business.
{"title":"The Legal Aspects of Corporate Social Responsibility: Interview with Ursula Wynhoven","authors":"Benjamin Thompson, Erica Teeuwen, Ilina Georgieva","doi":"10.5334/UJIEL.CH","DOIUrl":"https://doi.org/10.5334/UJIEL.CH","url":null,"abstract":"The Global Compact (UNGC) represents the world’s largest corporate citizenship initiative today. Created under the auspices of the United Nations (UN) to encourage companies around the world to adopt sustainable and socially responsible policies, the UNGC brings together businesses, UN agencies and labour groups in search of compromises. In a phone interview with the Journal’s team, Ursula Wynhoven, General Counsel and Head of the UN Global Compact, shared her views on current issues and challenges of the field. Before joining the UN, she was engaged with the Organisation for Economic Co-operation and Development (OECD) on the development of the OECD Guidelines for Multinational Enterprises (MNEs). Ursula Wynhoven has also worked as a lawyer in governmental human rights agencies and private practices in the United Kingdom, the United States and Australia, and is an adjunct professor at the University of Reykjavik’s School of Law in human rights and business.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726405","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Editorial: "We stand at a critical moment in Earth’s history, a time when humanity must choose its future. As the world becomes increasingly interdependent and fragile, the future at once holds great peril and great promise. To move forward we must recognize that in the midst of a magnificent diversity of cultures and life forms we are one human family and one Earth community with a common destiny." -Preamble of the Earth Charter
{"title":"Legal Aspects of Corporate Social Responsibility","authors":"T. Lambooy","doi":"10.5334/UJIEL.BZ","DOIUrl":"https://doi.org/10.5334/UJIEL.BZ","url":null,"abstract":"Editorial: \"We stand at a critical moment in Earth’s history, a time when humanity must choose its future. As the world becomes increasingly interdependent and fragile, the future at once holds great peril and great promise. To move forward we must recognize that in the midst of a magnificent diversity of cultures and life forms we are one human family and one Earth community with a common destiny.\" -Preamble of the Earth Charter","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70725697","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Book Review of: Corporate Social Responsibility of Multinational Corporations in Developing Countries: Perspectives on Anti-Corruption, Adefolake O. Adeyeye, Cambridge University Press.
《发展中国家跨国公司的企业社会责任:反腐败视角》，阿德福莱克·阿德耶耶著，剑桥大学出版社。
{"title":"Corporate Social Responsibility of Multinational Corporations in Developing Countries: Perspectives on Anti-Corruption","authors":"R. Ako","doi":"10.5334/UJIEL.CG","DOIUrl":"https://doi.org/10.5334/UJIEL.CG","url":null,"abstract":"Book Review of: Corporate Social Responsibility of Multinational Corporations in Developing Countries: Perspectives on Anti-Corruption, Adefolake O. Adeyeye, Cambridge University Press.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726352","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The recent decision in the US Supreme Court Kiobel case applied the presumption against extraterritoriality towards the Alien Tort Statute, decreasing the potential scope of tort actions that can be made against corporations for severe human rights violations. In light of the growing influence of multinational corporations and the lack of any international law regime to regulate corporate wrongdoing, this decision might be seen as a blow against one of the few potential avenues for justice for those victims of corporate human rights violations. The Alien Tort Statute is not a jurisdictional statute that allows for claims under international law but is rather a uniquely American cause of action unconnected to international law. The question remains whether an extension of American law to provide remedies for severe corporate human rights abuses can be justified in the absence of any such remedies existent in international law. This article will attempt to answer this question applying criteria developed by leading scholars in response to American exceptionalism. It will argue that the Kiobel decision, rather than being detrimental to holding corporations accountable, actually addresses many of the negative aspects of extraterritorial litigation whilst preserving some possibility of remedy for victims of severe human rights violations by corporations.
{"title":"Was Kiobel Detrimental to Corporate Social Responsibility? Applying Lessons Learnt from American Exceptionalism","authors":"Benjamin Thompson","doi":"10.5334/UJIEL.CE","DOIUrl":"https://doi.org/10.5334/UJIEL.CE","url":null,"abstract":"The recent decision in the US Supreme Court Kiobel case applied the presumption against extraterritoriality towards the Alien Tort Statute, decreasing the potential scope of tort actions that can be made against corporations for severe human rights violations. In light of the growing influence of multinational corporations and the lack of any international law regime to regulate corporate wrongdoing, this decision might be seen as a blow against one of the few potential avenues for justice for those victims of corporate human rights violations. The Alien Tort Statute is not a jurisdictional statute that allows for claims under international law but is rather a uniquely American cause of action unconnected to international law. The question remains whether an extension of American law to provide remedies for severe corporate human rights abuses can be justified in the absence of any such remedies existent in international law. This article will attempt to answer this question applying criteria developed by leading scholars in response to American exceptionalism. It will argue that the Kiobel decision, rather than being detrimental to holding corporations accountable, actually addresses many of the negative aspects of extraterritorial litigation whilst preserving some possibility of remedy for victims of severe human rights violations by corporations.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726182","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
According to climate science and the 195 signatory States to the UN Climate Convention, every emission of anthropogenic greenhouse gases contributes to climate change. Furthermore, they hold that a two degree Celsius rise of Earth’s average temperature is to be considered as a dangerous climate change to mankind and all of the world’s ecosystems. Using the climate proceedings of Dutch citizens against the Dutch state as a starting point, the author of this case note explains why each European Member State’s contribution to dangerous climate change as a result of inadequate emission reduction policies constitutes a tort of negligence against its citizens and poses a real threat for its citizens’ effective enjoyment of human rights. The author argues that this makes individual European Nations severally liable for dangerous climate change and gives European citizens and non-governmental organisations the possibility to request their Nation State’s competent court to compel the Nation’s government to implement stricter emission reductions in accordance with what is deemed necessary to help avoid dangerous climate change and to protect their human rights.
{"title":"The Liability of European States for Climate Change","authors":"R. Cox","doi":"10.5334/UJIEL.CI","DOIUrl":"https://doi.org/10.5334/UJIEL.CI","url":null,"abstract":"According to climate science and the 195 signatory States to the UN Climate Convention, every emission of anthropogenic greenhouse gases contributes to climate change. Furthermore, they hold that a two degree Celsius rise of Earth’s average temperature is to be considered as a dangerous climate change to mankind and all of the world’s ecosystems. Using the climate proceedings of Dutch citizens against the Dutch state as a starting point, the author of this case note explains why each European Member State’s contribution to dangerous climate change as a result of inadequate emission reduction policies constitutes a tort of negligence against its citizens and poses a real threat for its citizens’ effective enjoyment of human rights. The author argues that this makes individual European Nations severally liable for dangerous climate change and gives European citizens and non-governmental organisations the possibility to request their Nation State’s competent court to compel the Nation’s government to implement stricter emission reductions in accordance with what is deemed necessary to help avoid dangerous climate change and to protect their human rights.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726445","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The OECD Guidelines for Multinational Enterprises were viewed at their genesis as political commitments not legally binding on states and only voluntary for corporations. Due to the OECD Council Decision on the Guidelines for Multinational Enterprises in 2000/2011, however, OECD Member States are compelled to implement this regime by the establishment and operation of a National Contact Point (NCP) as a state-based, non-judicial, dispute resolution mechanism to handle complaints concerning corporations operating from or within their respective jurisdictions. This paper does not analyse weaknesses in the often-troubled NCP system nor does it propose reforms. Rather, it examines the current system from the legal perspective of OECD Member States and explores the relatively ignored extent of their obligations under it. This paper posits that on account of the Council Decision, treaty-derived, international obligations are in fact imposed on OECD Member States under the NCP system and that NCP maladministration can lead to state responsibility at international law. In any event, however, it seems clear that there does not exist any review mechanism—domestically or internationally—capable of attributing internationally wrongful conduct to an OECD Member State on account of its NCP.
{"title":"International Obligations, State Responsibility and Judicial Review Under the OECD Guidelines for Multinational Enterprises Regime","authors":"S. Robinson","doi":"10.5334/UJIEL.CD","DOIUrl":"https://doi.org/10.5334/UJIEL.CD","url":null,"abstract":"The OECD Guidelines for Multinational Enterprises were viewed at their genesis as political commitments not legally binding on states and only voluntary for corporations. Due to the OECD Council Decision on the Guidelines for Multinational Enterprises in 2000/2011, however, OECD Member States are compelled to implement this regime by the establishment and operation of a National Contact Point (NCP) as a state-based, non-judicial, dispute resolution mechanism to handle complaints concerning corporations operating from or within their respective jurisdictions. This paper does not analyse weaknesses in the often-troubled NCP system nor does it propose reforms. Rather, it examines the current system from the legal perspective of OECD Member States and explores the relatively ignored extent of their obligations under it. This paper posits that on account of the Council Decision, treaty-derived, international obligations are in fact imposed on OECD Member States under the NCP system and that NCP maladministration can lead to state responsibility at international law. In any event, however, it seems clear that there does not exist any review mechanism—domestically or internationally—capable of attributing internationally wrongful conduct to an OECD Member State on account of its NCP.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726608","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Against a common perception of CSR being a business concept without binding legal effect, this article discusses legitimate legal effects of private standards in public international law, using the issue of private labels as “international standards” under WTO law. WTO law shows certain openness for external transnational standards. This article argues that the references to “international standards” in the TBT Agreement can be applied for the selection between competing public or private norms that claim relevance. Thereby, the most legitimate standard for governing the problem at issue should be chosen. This is exemplified with the case of Tuna Dolphin II where the Appellate Body has emphasised the requirement of procedural legitimacy. The article argues that the requirements for legitimate standards depend on the interests at stake and that a private standard can well be more legitimate than a (competing) public standard. As the justifying effect of Article 2.5 TBT mainly interferes with economic interests, a relevant “international standard” may well consist of a representative business standard, e.g. a private label. In contrast, an international standard in the terms of Article 2.4 TBT which interferes with a democratic decision in favour of public interests such as environmental protection must reflect these public interests in a legitimate way. The article concludes that CSR can play an important role in defining legally valid justifying or minimum standards in public international law.
{"title":"Competing Transnational Regimes under WTO Law","authors":"C. Glinski","doi":"10.5334/UJIEL.CC","DOIUrl":"https://doi.org/10.5334/UJIEL.CC","url":null,"abstract":"Against a common perception of CSR being a business concept without binding legal effect, this article discusses legitimate legal effects of private standards in public international law, using the issue of private labels as “international standards” under WTO law. WTO law shows certain openness for external transnational standards. This article argues that the references to “international standards” in the TBT Agreement can be applied for the selection between competing public or private norms that claim relevance. Thereby, the most legitimate standard for governing the problem at issue should be chosen. This is exemplified with the case of Tuna Dolphin II where the Appellate Body has emphasised the requirement of procedural legitimacy. The article argues that the requirements for legitimate standards depend on the interests at stake and that a private standard can well be more legitimate than a (competing) public standard. As the justifying effect of Article 2.5 TBT mainly interferes with economic interests, a relevant “international standard” may well consist of a representative business standard, e.g. a private label. In contrast, an international standard in the terms of Article 2.4 TBT which interferes with a democratic decision in favour of public interests such as environmental protection must reflect these public interests in a legitimate way. The article concludes that CSR can play an important role in defining legally valid justifying or minimum standards in public international law.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70725787","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Multi-national enterprises (MNEs) have provided substantial sponsorship for the Sochi Winter Olympic Games despite a host-country government that has recently enacted stunningly harsh legislation aimed at the Lesbian, Gay, Bisexual, Transgender, and Intersex (LGBTI) communities within Russia. This is a Corporate Social Responsibility (CSR) problem. Should Europe address it through voluntary corporate compliance, Europe’s historically preferred mode of promoting CSR? Or should Europe reconsider whether it can more effectively promote CSR compliance legislatively – and if so, by what kind of legislation? To honor the explicit and increased protections of human rights against sexual orientation discrimination in the Treaty of Amsterdam and the Charter of Fundamental Human Rights, more than voluntary, good intentions are needed. Particularly since the United States has effectively bowed out of enforcing CSR through the American federal courts, there now exists a regulatory lacuna that the European Commission is best situated to fill through the precision offered by judicious rulemaking. The article ultimately proposes an approach that combines the public-pressure engine that fuels voluntary CSR with public disclosures mandated by law to optimize the information and mobilization of public opinion and pressure – factors particularly noteworthy given the powerful “branding” benefits that MNEs seek through Olympic sponsorship.
{"title":"Sexual Orientation, Human Rights, and Corporate Sponsorship of the Sochi Olympic Games: Rethinking the Voluntary Approach to Corporate Social Responsibility","authors":"Jeffrey A. Van Detta","doi":"10.5334/UJIEL.CF","DOIUrl":"https://doi.org/10.5334/UJIEL.CF","url":null,"abstract":"Multi-national enterprises (MNEs) have provided substantial sponsorship for the Sochi Winter Olympic Games despite a host-country government that has recently enacted stunningly harsh legislation aimed at the Lesbian, Gay, Bisexual, Transgender, and Intersex (LGBTI) communities within Russia. This is a Corporate Social Responsibility (CSR) problem. Should Europe address it through voluntary corporate compliance, Europe’s historically preferred mode of promoting CSR? Or should Europe reconsider whether it can more effectively promote CSR compliance legislatively – and if so, by what kind of legislation? To honor the explicit and increased protections of human rights against sexual orientation discrimination in the Treaty of Amsterdam and the Charter of Fundamental Human Rights, more than voluntary, good intentions are needed. Particularly since the United States has effectively bowed out of enforcing CSR through the American federal courts, there now exists a regulatory lacuna that the European Commission is best situated to fill through the precision offered by judicious rulemaking. The article ultimately proposes an approach that combines the public-pressure engine that fuels voluntary CSR with public disclosures mandated by law to optimize the information and mobilization of public opinion and pressure – factors particularly noteworthy given the powerful “branding” benefits that MNEs seek through Olympic sponsorship.","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2014-02-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726294","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Traditionally, in the Netherlands the idea was that political parties were essentially private associations in whose internal affairs the state ought not to interfere. However, the case of the Staatkundig Gereformeerde Partij (Political Reformed Party, hereafter, SGP) has led to a political and public debate on whether this view can be maintained. This article examines the case of the SGP, particularly from the viewpoint of democratic theory. It eventually concludes that party regulation does not need to remain a taboo topic forever, even in the Netherlands, although with the SGP having recently changed its own constitution it may take a while until further provisions will be introduced. Care should be taken, however, that it does not lead to unnecessary infringements on the constitutional freedoms of minorities such as the SGP and its followers. After all, what is the point in pursuing non-discriminatory policies that are themselves discriminatory?
{"title":"The Dutch Political Reformed Party (SGP) and Passive Female Suffrage: A Comparison of Three High Court Judgments From the Viewpoint of Democratic Theory","authors":"J. D. Brink, H. T. Napel","doi":"10.5334/UJIEL.BU","DOIUrl":"https://doi.org/10.5334/UJIEL.BU","url":null,"abstract":"Traditionally, in the Netherlands the idea was that political parties were essentially private associations in whose internal affairs the state ought not to interfere. However, the case of the Staatkundig Gereformeerde Partij (Political Reformed Party, hereafter, SGP) has led to a political and public debate on whether this view can be maintained. This article examines the case of the SGP, particularly from the viewpoint of democratic theory. It eventually concludes that party regulation does not need to remain a taboo topic forever, even in the Netherlands, although with the SGP having recently changed its own constitution it may take a while until further provisions will be introduced. Care should be taken, however, that it does not lead to unnecessary infringements on the constitutional freedoms of minorities such as the SGP and its followers. After all, what is the point in pursuing non-discriminatory policies that are themselves discriminatory?","PeriodicalId":30606,"journal":{"name":"Utrecht Journal of International and European Law","volume":null,"pages":null},"PeriodicalIF":0.6,"publicationDate":"2013-07-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"70726120","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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