TC0-09675

RAD File / Dossier de la SAR: TC0-09675 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person who is the subject of the appeal XXXX XXXX XXXX Personne en cause Appeal considered / heard at Toronto, ON Appel instruit / entendu à Date of decision April 9, 2021 Date de la décision Panel J. Pollock Tribunal Counsel for the person who is the subject of the appeal Shelley S Levine Conseil de la personne en cause Designated representative N/A Représentant(e) désigné(e) Counsel for the Minister N/A Conseil du ministre REASONS FOR DECISION OVERVIEW [1] These are my reasons for dismissing the appeal of XXXX XXXX XXXX (the Appellant) confirming the decision of the Refugee Protection Division (RPD) that he is neither a Convention refugee nor a person in need of protection. [2] The Appellant is a citizen of China. He alleges a fear of returning to China as a Falun Gong practitioner. In his Basis of Claim (BOC) form, he alleges that he began practicing Falun Gong in China in XXXX 2018. He alleges that his practice group was raided by the authorities and he escaped and went into hiding. He alleges that the Public Security Bureau (PSB) went to his house looking for him. He left for Canada in XXXX 2018. [3] The RPD rejected the Appellant's claim, finding him lacking in credibility. The RPD made the following findings about the Appellant's evidence: (1) He was inconsistent about when he alleges that he began practicing Falun Gong; (2) He could not provide the purpose of the Falun Gong exercise that he alleged he practiced most often; (4) He could not explain why practitioners send righteous thoughts and he does not send righteous thoughts; and (5) He failed to establish a sur place claim and his support letter is entitled to no weight.1 The Appellant argues that the RPD decision is incorrect. He has not submitted new evidence, and I have no jurisdiction to hold a hearing.2 [4] Having independently assessed all the evidence, including the complete RPD hearing audio-recording, I find that the RPD's overall credibility finding is correct. I find that the Appellant has failed to credibly establish, on a balance of probabilities, that he is a genuine Falun Gong practitioner or that he would be perceived as such by Chinese authorities, such that he faces a serious possibility of persecution or a subsection 97(1) risk. DECISION [5] I dismiss the appeal. The RPD was correct in finding that the Appellant is neither a Convention refugee nor a person in need of protection. ANALYSIS [6] I am reviewing the RPD's decision on the standard of correctness as I do not find the RPD enjoyed a meaningful advantage. I have conducted an independent assessment of the evidence to determine whether, as submitted by the Appellant, the RPD erred.3 The Appellant is responsible for raising any potential grounds of appeal that arise from the RPD decision.4 Issues on appeal [7] The Appellant argues that the RPD erred, as follows: * In assessing his knowledge of Falun Gong through a trivia contest; * In failing to determine whether he joined Falun Gong for political reasons and to socialize with anti-government community members; and * In misstating the law on sur place claims and failing to conduct a separate analysis of his sur place claim, apart from its findings regarding his practice in China.5 [8] In assessing whether there are valid reasons to doubt the Appellant's credibility, I am mindful of the difficulties in establishing a claim, including nervousness in the hearing room and the difficulty of testifying with the assistance of an interpreter. I also acknowledge that the Appellant has five years of formal education.6 No medical evidence was provided regarding any cognitive and/or memory impairments. After listening to the complete RPD hearing audio-recording and independently assessing all the evidence, I find that material credibility concerns were not reasonably explained, and that the presumption of truthfulness is rebutted. I find that the Appellant failed to credibly establish, on a balance of probabilities, that he is a genuine Falun Gong practitioner, or that he would be perceived as such by Chinese authorities, such that he faces a serious possibility of persecution or a personal subsection 97(1) risk. The Appellant failed to credibly establish that he is a genuine Falun Gong practitioner The Appellant's inconsistency about when he began practicing Falun Going [9] The RPD identified a material credibility concern in the Appellant's testimony about the year that he began practicing Falun Gong. Counsel does not identify any error in this RPD finding, and I find none in my independent assessment. This RPD finding is correct. [10] In his BOC, the Appellant alleges that he was introduced to Falun Gong in China in XXXX 2018 and began practicing thereafter.7 However, in testimony he alleged that he began practicing Falun Gong in XXXX 2017.8 Then he changed his testimony, alleging that it may have been in 2016 or 2017, but that he has forgotten.9 When confronted with the inconsistency with his BOC and earlier testimony, he alleged that he has forgotten but he probably began practicing in XXXX.10 Then he changed his testimony again, alleging: "In 2016 I began to have an interaction with Falun Gong, in 2018 I formally began to practice."11 He also explained that his BOC was incorrect because he had just arrived in Vancouver, he was scared, and he could not understand the interpreter from Hong Kong that he was provided.12 However, his BOC was not completed the day he arrived in Canada. Rather, it was completed nearly two weeks later with the assistance of his Counsel and a Mandarin interpreter.13 When confronted with his earlier testimony that his BOC was complete, true, and correct, he did not offer an explanation.14 [11] Having independently assessed the evidence, I find that the RPD correctly considered and rejected the Appellant's explanations for these inconsistencies. It is reasonable to expect the Appellant to consistently recall the year that he first began practicing Falun Gong. This is not minor or peripheral in nature and it goes to the heart of his claim. The difference in the dates is as much as two years - from 2016 to 2018. In addition, the Appellant had the assistance of an interpreter and his Counsel in preparing his BOC. He confirmed under oath before the RPD that all the information in his BOC is complete, true, and correct.15 The Appellant's Falun Gong knowledge is not consistent with his alleged practice history [12] The RPD identified a number of material credibility concerns about the Appellant's Falun Gong knowledge.16 Counsel argues that the RPD erred when it assessed the Appellant's claim through a trivia contest and failed to recognize that practitioners have different levels of knowledge depending on their personal experience. While I agree that the inquiry into the sincerity of the Appellant's religious beliefs must be approached with caution, I am not persuaded by Counsel's argument that the RPD's approach was incorrect. I find that the RPD was not microscopic and it did not expect an unrealistically high level of knowledge. [13] I have undertaken an independent assessment of the Appellant's alleged frequency and duration of Falun Gong practice. As previously discussed, the Appellant's evidence about when he began practicing Falun Gong differs considerably between his BOC and testimony. He alleges a practice history anywhere from just under two years to nearly 4 years at the time of his February 2020 RPD hearing. I have also considered the Appellant's level of allegation. While he has five years of formal education, he claims to have studied with the assistance of others, not in isolation. Specifically, he alleges attending 30 to 50 Falun Gong group practice sessions in China and 20 group practice sessions in Canada.17 He also alleged that he listens to Falun Gong theory.18 Based on my independent assessment of the Record, I find that the Appellant's unfamiliarity with foundational Falun Gong tenets is not consistent with his alleged practice history. I find that he is not credible and that he is not a genuine Falun Gong practitioner. [14] Exercise three: The Appellant alleged that when he engages in group practice in Canada, he does exercise one and three, but sometimes they only do exercise three.19 However, he was unable to articulate the purpose of exercise three. While he alleged that this exercise is to "get rid of the karma out of me" and to "get rid of something bad," this is inconsistent with Falun Gong teachings.20 The documentary evidence indicates that "the purpose of this exercise is to mix and merge the universe's energy with the energy inside the body" and it "facilitates the 'opening of the top of the head' and unblocks the passages under the feet."21 The RPD drew an adverse credibility inference based on the Appellant's inability to correctly identify the purpose of the exercise he does most often. I find no error in the RPD's approach. Where the Appellant alleges that he engages in exercise three most often in Canada, I find that the RPD was correct to expect that he would be able to identify its purpose. In my independent assessment, I agree with the RPD's finding. As the RPD correctly notes in its decision, the foundation of Falun Gong is based on a body of fundamental knowledge, essential for the task of undertaking proper cultivation.22 [15] Exercise one: The Appellant was also unable to identify the purpose of exercise one, explaining that he does not know.23 As the RPD correctly noted, the objective evidence indicates that there are a total of five Falun Gong exercises and that each have unique and specific purposes.24 I find no error in the RPD's approach. In my independent assessment, I find that it is reasonable to expect the Appellant to demonstrate knowledge about exercise one given that he alleges that he practices this exercise with a group in Canada.25 I concur with the RPD's finding. [16] Righteous thoughts: The Appellant was also unable to describe why practitioners send righteous thoughts, explaining that he works so much, and he has only had time to send righteous thoughts twice in Canada.26 The RPD drew an adverse credibility inference on this basis, noting that the documentary evidence indicates that Master Li has explained the purpose of righteous thoughts and provided instructions for sending forth righteous thoughts.27 I find no error in the RPD's approach. In my independent assessment, I find that it is reasonable to expect the Appellant to demonstrate some knowledge about righteous thoughts. Having independently assessed the objective evidence, I also agree with the RPD's finding about the importance of sending righteous thoughts in Falun Gong and that it is done to stop the persecution of fellow practitioners.28 Master Li notes that Falun Gong practitioners "have to take sending righteous thoughts very seriously, and in a timely manner purge the evil and your own problems so that you won't be taken advantage of by the evil."29 He also notes that righteous thoughts should be sent "on a daily basis."30 In my view, the RPD was also correct to reject the Appellant's explanation that he works too much to send righteous thoughts. Master Li instructs practitioners that they can adjust the method in order to send them in the workplace, as follows: When you send righteous thoughts, no matter how intense things get, the surface should be serene. This especially applies when you're at your workplace or in some other particular setting; you don't need to hold your palm erect and the results will be the same. As long as you keep your righteous thoughts strong and focus your mind you can achieve the same results.31 [17] In Gao, the Federal Court held that it was open to the RAD to impugn an Appellant's credibility based on his inability to adequately explain righteous thoughts, noting that this is a "rudimentary concept of his faith."32 The RPD's finding is correct. [18] A Claimant's poor understanding of religious doctrine does not necessarily mean that their faith is not genuine. However, a Claimant's "inconsistent, vague, non-responsive or contradictory answers" may properly support a negative credibility finding about the sincerity of their beliefs.33 The RPD is "entitled to consider whether the claimant holds a level of religious knowledge that would be expected of someone in the claimant's position but should not reach an adverse conclusion based on minutiae or holding the claimant to an unreasonably high standard of religious knowledge."34 What matters is not just the incorrectness of the answers, but also "the details, comfort, and sense of familiarity conveyed."35 In my independent assessment, the Appellant has demonstrated a lack of familiarity with Falun Gong knowledge and he has not credibly demonstrated his pursuit of Falun Gong in Canada. [19] In a RAD Reason of Interest, another RAD panel notes that "Falun Gong is a knowledge-based practice that combines certain key tenets with the physical practice of five exercises; 'the foundation of Falun Dafa [Falun Gong] consists of a body of fundamental knowledge essential for the task of undertaking proper cultivation towards higher stages of attainment.'"36 I agree. A Claimant's "efforts to grow in knowledge is an indication of sincerity of belief" and "there is an expectation that a genuine practitioner would make efforts to grow in their understanding of this faith system from the time they begin their practice."37 [20] In my view, the RPD did not assess the Appellant's knowledge of Falun Gong microscopically and it did not adopt an unrealistically high standard of knowledge. Rather, the RPD focused on the Appellant's unfamiliarity with foundational tenets. When the Appellant was asked basic questions about his faith, his answers were inconsistent or non-responsive. His familiarity with Falun Gong is not consistent with his alleged practice history. Falun Gong activity to socialize with anti-government community not established [21] Counsel argues that the RPD was required to "consider alternative motives for membership" and that the RPD failed to determine whether the Appellant joined Falun Gong for political reasons and to socialize with anti-government community members.38 I disagree. [22] Counsel has not pointed to any evidence on Record that would support a political or social motivation. Having independently assessed all the evidence, I note that the Appellant did not allege that he joined Falun Gong for political reasons or to socialize with anti-government community members in his BOC, which was prepared with Counsel, or in testimony before the RPD. Rather, he alleged in his BOC and testimony that he joined Falun Gong in order to address his post-divorce unhappiness; he alleged that his practice led to the disappearance of his bad mood and helped him feel relaxed.39 Counsel has failed to explain why this alleged political and social motivation for joining Falun Gong is only being offered now on appeal, in his memorandum before the RAD. An appeal is not meant to provide opportunities to add testimony or explanations that could have been provided before the RPD rejection, or to supplement a deficient RPD Record.40 I am not persuaded by Counsel's argument. The RPD did not err. The RPD erred in assessing the Appellant's single support letter [23] The RPD accorded no weight to the single support letter the Appellant provided in support of his claim because "it is not a not sworn statement, the author was not at the hearing to testify and the handwritten letter could have been written by anyone from anywhere."41 Having undertaken an independent assessment, I find that the RPD erred. While the letter is not sworn, there is no requirement for supporting statements to be sworn. It is also an error to impugn a support letter because it was not subject to cross-examination. As confirmed by the Federal Court of Appeal, "it is not for the Refugee Division to impose on itself or claimants evidentiary fetters from which Parliament has freed them."42 I set aside and do not rely on this RPD finding. [24] In undertaking my independent assessment of the Appellant's letter of support on appeal, I can correct the RPD's error. The author of this letter, G.T.,43 explains that they are a Falun Gong practitioner and that they met the Appellant in XXXX 2018 during practice at XXXX XXXX.44 G.T. explains that the Appellant is a "real Falun Gong practitioner" and that they "went to speak truth and joined all the activities of Falun Gong."45 While G.T. also explains that they "often practiced Falun Gong on Saturdays and Sundays and exchanged or study experience,"46 the Appellant's knowledge of basic principles is very limited, as described earlier in my Reasons. Moreover, the letter is undated. Therefore, it is not clear how frequently the Appellant practiced or studied with G.T. Even where the Appellant represented himself as a genuine Falun Gong practitioner to G.T., this letter does not establish the sincerity of the Appellant's practice. I find that the Appellant is not credible in his self-reporting and representation of practice as genuine. I accord G.T.'s letter little weight to corroborate the Appellant's genuine practice in Canada. The Appellant failed to credibly establish a sur place claim [25] The RPD identified material credibility concerns in the Appellant's testimony and it found that he was not a genuine practitioner in China or a genuine practitioner in Canada.47 Counsel argues that "the RPD was obliged to conduct a separate analysis of the sur place claim, apart from its findings in regard to the Appellant's practice in China."48 I disagree. It is well established that a Claimant's impugned motive for engaging in religious practice can inform an assessment of the genuineness of their practice in Canada.49 As such, it was open to the RPD to assess the genuineness of the Appellant's religious faith in light of its credibility concerns relating to the original credibility of his claim.50 As the Federal Court found in Gao, where an Applicant's practice in China has been found not credible, and they claim that their Canadian practice is a continuation of their Chinese practice, it is open to the RAD to question the credibility of their practice in Canada.51 Counsel argues that "a claimant's conversion to a religion in Canada can give rise to a sur place claim."52 However, the Appellant has not alleged a conversion in Canada; rather, his Falun Gong practice - much like the Applicant's practice in Gao - is alleged to be a continuation of his practice in China. [26] Counsel also argues that the RPD's sur place analysis is in error because the RPD "never bothered to ask the Appellant any questions about why he was a practitioner, whether his intentions were genuine or how the practice impacted his life."53 I am not persuaded by Counsel's argument. During the RPD hearing, the Appellant was asked questions about these issues, including why he joined Falun Gong, how the practice made him feel, and why he chose Falun Gong over other meditation practices.54 Counsel had the opportunity to ask further questions at the RPD hearing if he believed additional testimony on these issues was required. [27] Counsel also argues that the RPD erred when it implied "that a sur place claim can only succeed where the Appellant's sur place activities in Canada have come to the attention of the authorities in China."55 I agree. The RPD found that the Appellant's sur place claim fails partly because his Falun Gong activities have not come to the attention of Chinese authorities.56 I set aside and do not rely on this RPD finding. In undertaking my independent assessment on appeal, I can correct the RPD's error. Having independently assessed all the evidence, I find that the Appellant has not credibly established a sur place claim. [28] The question to be asked for a sur place claim is whether a Claimant's activities are "likely to come to the attention" of the authorities in the Claimant's home country and whether this gives rise to a serious possibility of persecution.57 The determination of whether a Claimant's activities in Canada would come to the attention of authorities in their home country is a factual finding made on a balance of probabilities.58 [29] In accordance with Federal Court jurisprudence, I have considered whether the Appellant has presented evidence of detailed and genuine of Falun Gong knowledge and persistent practice in Canada.59 I find that he has not. His unfamiliarity with foundational tenets is not consistent with his alleged practice history and undermines the credibility of his sur place claim. His Falun Gong knowledge and activities in Canada are insufficient to establish his genuine practice. [30] I find that the Appellant has presented insufficient evidence to establish that he would be a person of interest for Chinese authorities upon return, such that he faces a serious possibility of persecution or a subsection 97(1) risk. Counsel argues that the Appellant is perceived as a practitioner as a result of his association with Falun Gong.60 I disagree. While there is evidence on Record that Chinese authorities have used surveillance at some Falun Gong events, there is no evidence to suggest that the Appellant's limited participation in the Falun Gong community in Canada has or is more likely than not to come to the attention of Chinese authorities. SUMMARY [31] After independently assessing all the evidence, I find that the Appellant's allegations are, on a balance of probabilities, not credible. The RPD was correct in finding that he failed to credibly establish that he is a genuine Falun Gong practitioner or would be perceived as such by Chinese authorities. I find that the Appellant has not credibly established that he faces a serious possibility of persecution, or a personal subsection 97(1) risk, upon return to China. CONCLUSION [32] I dismiss the appeal and confirm the decision of the RPD that the Appellant is neither a Convention refugee nor a person in need of protection. (signed) "J. Pollock" J. Pollock April 9, 2021 Date 1 Exhibit RPD-1, RPD Record, RPD Decision, at paras. 8-30. 2 Immigration and Refugee Protection Act (IRPA), SC 2001, c 27, as amended, at ss. 110(6). 3 Canada (MCI) v. Huruglica, 2016 FCA 93, at para. 103. 4 Ilias v. Canada (MCI), 2018 FC 661, at para. 39; Kanawati v. Canada (MCI), 2020 FC 12, at para. 23; Marinaj v. Canada (MCI), 2020 FC 548, at para. 41; Akintola v. Canada (MCI), 2020 FC 971, at para. 21 5 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at paras. 6-7, 11-34. 6 Exhibit RPD-1, RPD Record, Exhibit 1, at p. 49, at question 5. 7 Exhibit RPD-1, RPD Record, Exhibit 2, at p. 22, at paras. 5-6. 8 RPD hearing audio-recording, February 11, 2020 at 00:20:47. 9 RPD hearing audio-recording, February 11, 2020 at 00:24:00-00:24:25. 10 RPD hearing audio-recording, February 11, 2020 at 00:24:36-00:24:53. 11 RPD hearing audio-recording, February 11, 2020 at 00:26:04-00:26:14. 12 RPD hearing audio-recording, February 11, 2020 at 00:31:29-00:32:27. 13 Exhibit RPD-1, RPD Record, Exhibit 2, at p. 21, at question 9, at p. 24, at questions 11, 12. 14 RPD hearing audio-recording, February 11, 2020 at 00:32:30-:00:33:00. 15 RPD hearing audio-recording, February 11, 2020 at 00:03:03-00:03:24. 16 Exhibit RPD-1, RPD Record, RPD Decision, at paras. 9-28. 17 RPD hearing audio-recording, February 11, 2020 at 00:22:30-00:23:00; 00:39:30-00:40:02. 18 RPD hearing audio-recording, February 11, 2020 at 00:55:10. 19 RPD hearing audio-recording, February 11, 2020 at 00:39:00-00:39:31. 20 RPD hearing audio-recording, February 11, 2020 at 00:43:34-00:44:18. 21 Exhibit RPD-1, RPD Record, Exhibit 3, National Documentation Package (NDP) for China (20 December 2019), Item 12.7, at p. 52. 22 Exhibit RPD-1, RPD Record, RPD Decision, at para. 17; Exhibit 3, NDP for China (20 December 2019), Item 12.32; Item 12.9. 23 RPD hearing audio-recording, February 11, 2020 at 00:45:15-00:45:35. 24 Exhibit RPD-1, RPD Record, RPD Decision, at para. 23; Exhibit 3, NDP for China (20 December 2019), Item 12.7. 25 RPD hearing audio-recording, February 11, 2020 at 00:39:00-00:39:12. 26 RPD hearing audio-recording, February 11, 2020 at 00:45:42-00:46:59. 27 Exhibit RPD-1, RPD Record, RPD Decision, at paras. 24-26. 28 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (20 December 2019), Item 12.25. 29 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (20 December 2019), Item 12.25. 30 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (20 December 2019), Item 12.25. 31 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (20 December 2019), Item 12.25. 32 Gao v. Canada (MCI), 2021 FC 271, at para. 27; Wang v. Canada (MCI), 2018 FC 668, at paras 29-39; Zheng v. Canada (MCI), 2019 FC 731, at para 17. 33 Ren v. Canada (MCI), 2015 FC 1402, at para. 19. 34 Gao v. Canada (MCI), 2015 FC 1139, at para. 26. 35 Liang v. Canada (MCI), 2017 FC 1020, at para. 19. 36 RAD Decision identified as a RAD Reason of Interest, X (Re), 2018 CanLII 97031 (CA IRB), at para. 12; Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (20 December 2019), Item 12.9. 37 X (Re), 2019 CanLII 136706 (CA IRB), at para. 19. 38 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at paras. 14, 22, 24(b). 39 Exhibit RPD-1, RPD Record, Exhibit 2, at p. 22, at paras. 4-5, at p. 23, at para. 7; RPD hearing audio-recording, February 11, 2020 at 00:53:29. 40 Canada (MCI) v. Singh, 2016 FCA 96, at para. 54. 41 Exhibit RPD-1, RPD Record, RPD Decision, at para. 29. 42 Fajardo v. Canada (MEI) (1993), 157 NR 392 (FCA); Shahaj v. Canada (MCI), 2005 FC 1044, at para. 9; Amaya v. Canada (MCI), 1999 CanLII 7365, at para. 19; IRPA, at ss. 170(g), ss. 171(a.2). 43 Personal identifiers have been removed, except where necessary to explain the reasoning of the decision. 44 Exhibit RPD-1, RPD Record, Exhibit 6, at p. 167. 45 Exhibit RPD-1, RPD Record, Exhibit 6, at p. 167. 46 Exhibit RPD-1, RPD Record, Exhibit 6, at p. 167. 47 Exhibit RPD-1, RPD Record, RPD Decision, at para. 28. 48 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at paras. 24(b). 49 Chen v. Canada (MCI), 2014 FC 749, at para. 59. 50 Jiang v. Canada (MCI), 2012 FC 1067, at paras. 27-28; Hou v. Canada (MCI), 2012 FC 993, at para. 57; Yang v. Canada (MCI), 2012 FC 849, at para. 19; Liang v. Canada (MCI), 2017 FC 1020, at para. 19 ; Liang v. Canada (MCI), 2020 FC 720, at para. 29; Zheng v. Canada (MCI), 2019 FC 904, at paras. 23-28. 51 Gao v. Canada (MCI), 2021 FC 271, at para. 39. 52 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at para. 30. 53 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at paras. 24(a). 54 RPD hearing audio-recording, February 11, 2020 at 00:53:29-01:04:28. 55 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at para. 25. 56 Exhibit RPD-1, RPD Record, RPD Decision, at para. 30. 57 Win v. Canada (MCI), 2008 FC 398, at paras. 2, 30; Girmaeyesus v. Canada (MCI), 2010 FC 53, at para. 28. 58 Gebremedhin v. Canada (IRCC), 2017 FC 497, at para. 23, 29 59 Chen v. Canada (MCI), 2014 FC 749, at para. 59. 60 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at para. 22. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD File / Dossier de la SAR: TC0-09675 RAD.25.02 (January, 2020) Disponible en français 2 Immigration and Refugee Board of Canada Refugee Appeal Division Commission de l'immigration et du statut de réfugié du Canada Section d'appel des réfugiés RAD.25.02 (January, 2020) Disponible en français