IV. PRAYERS OF THE PARTIES 21. The Applicants request the Court to find that the Respondent State violated the rights referred to in paragraph 16 above and to order it to: i. Publicly acknowledge its responsibility for the violations referred to in the Application and publicly apologise, in particular to the victims of the toxic waste dumping and the consequences thereof; ii. Open an independent and impartial investigation in order to establish liability for the waste and prosecute persons involved for their criminal liability, regardless of their status or employment within TRAFIGURA or the office they hold in the country; iii. Ensure the provision of medical assistance to victims, including treatment of new symptoms, and in the long-term, illnesses caused by exposure to toxic waste, establish adequate health facilities and provide qualified personnel and appropriate equipment to provide the necessary care so as to improve the health of the victims of toxic waste; iv. Immediately roll out an adequate and effective compensation programme for victims of toxic waste, beginning with a national census of victims of waste dumping, taking into account the continuous presence of toxic waste for nearly a decade, and ensure that the result of this census is disseminated to the public, and to consult with the victims after the programme has been put in place, in order to determine a quantum of compensation that is commensurate with their expectations and needs; v. Immediately take measures to prepare a comprehensive national study on the health and environmental effects of dumping the toxic waste in the short, medium and long term, ensure that the study is widely disseminated and inform the public of measures taken to address the short, medium and long-term negative effects of toxic waste on human health and the environment; vi. Submit a transparent and publicly accessible report on the use of the lump sum allocated to Côte d’Ivoire under the Memorandum of Understanding signed with TRAFIGURA; and; vii. Implement structural reforms to enhance waste handling capacity in the port of Abidjan by adopting environmentally friendly methods, 8

Select target paragraph3