154 C. SANDELOWSKY-BOSMAN AND T. LIEFAARD appropriate measures to protect children with ties to the Netherlands from violations by third parties, i.e. State or non-State actors under the responsibility or control of other countries.96 How these obligations to act should be fulfilled specifically depends on the circumstances of the case and the law in question. The Dutch Government, for instance, could make efforts to improve the conditions in camps abroad or to invest in the relevant justice system. But it is doubtful whether this would adequately help the children in question (many of whom are very young), and whether it would do so fast enough. It would be more effective to assist in returning the children, for this would solve many problems immediately. The abovementioned obligation to act is substantiated in part by various (non-binding) recommendations from UN bodies. First, there are the recommendations recommendations of the CRC Committee to Belgium. In response to the Belgian decision to only repatriate Belgian children under the age of 10, the CRC recommended the repatriation of all children, irrespective of age, and where possible also their families.97 Consequently, the CRC appears to take the view – incidentally, without providing motivation – that Belgium has the responsibility to return all Belgian children. The question is what this implies for the Dutch Government. In addition, the UN Security Council encourages the facilitation of the return of the children98 and the UN Secretary-General has called on all countries of origin of the children who are staying in refugee camps to facilitate access to consular services.99 This also prompts the question of whether, given the growing international pressure on UN Member States, the policy of the Dutch Government will be sustainable for much longer. 4.4.2. Appropriate measures in the context of the obligation to protect against violations of children’s rights by State and non-State actors outside the territory of a State Party The reasonableness of expected measures also depends on any security risks to society identified by the Dutch Government, as well as any risks to international relations, to those who wish to return and to those who would be involved in a repatriation operation. It is difficult to gain a clear picture of these risks on the basis of the information that is available to the public, but the risks arising from the children themselves would appear to be very limited, particularly in the case of the younger children.100 One appropriate measure could be to draw up bilateral agreements. States Parties are obliged to enter into international cooperation where this appears necessary for the implementation of children’s rights (UNCRC, Article 4).101 The preamble to the UNCRC102 and certain UNCRC provisions refer explicitly to the need for international cooperation.103 In the words of the CRC: ‘ … the implementation of the Convention is 96 Ibid. 28; UNCRC, art 4. Concluding Observations on the Combined Fifth and Sixth Reports on Belgium, CRC/C/BEL/CO/5-6 (2019), 50(b). Belgium is still seeking to repatriate 42 children under the age of 10 from Northern Syria: Broches (n 12). 98 Resolution 2427, S/RES/2427 (2018) 26. 99 UN Security Council, Children and Armed Conflict in the Syrian Arab Republic. Report of the Secretary-General, S/2018/ 969 (2018) 65. See also European Parliament Resolution (n 13). 100 See ‘KNVIR Spring Meeting’ (n 83). It can also be asked if this applies to the parents of a child as well. 101 CRC Committee (n 95) 41. 102 See final paragraph of the UNCRC, Preamble. 103 See in addition to UNCRC, art 4, UNCRC, art 24(1) – which provides that States must encourage international cooperation in the context of the right to the highest attainable level of health. UNCRC, art 34 obliges States Parties to protect children 97