by the international system or for whom the government will be called to answer. 136. The term 'non-state actors' has therefore been adopted by the international community to refer to individuals, organisations, institutions and other bodies acting outside the State and its organs. They are not limited to individuals since some perpetrators of human rights abuses are organisations, corporations or other structures of business and finance, as the research on the human rights impacts of oil production or the development of power facilities demonstrates.34 Issue Two: Are the Zimbabwe African National Union-Patriotic Front - ZANU (PF) and the Zimbabwe Liberation War Veterans Association (War Veterans) non-state actors 137. By its submission of 23 February 2004, the Complainant argued that the Government of Zimbabwe planned, committed or otherwise aided and abetted a campaign of terror and violence...and stated further that the War Veterans and the supporters of the governing ZANU (PF) with endorsement and support of the government unlawfully occupied commercial farms... which were turned into torture and re-education camps. The Complainant argued further that "under the current political arrangement in Zimbabwe, ZANU (PF) is government and the government is ZANU (PF) and with respect to the war veterans, the Complainant submitted that "at all material times the government of Zimbabwe exercised extensive de jure and de facto control over the war veterans", noting that the Chairperson of the Zimbabwe Liberation War Veteran Association, Dr. Hunzvi made a statement in court to the effect that President Mugabe had control over the war veterans. The Complainant was therefore implying that the ZANU (PF) and the War Veterans were either State apparatus or were controlled by the Government. In its submission of 23 February 2004 the Complainant argued further that even if it were found that ZANU (PF) supporters and war veterans were not agents of the government, read together with the general obligation under Article 1 of the African Charter, the government could still be held liable for a violation of the Charter, noting that under Article 1 of the Charter, the government is required to take all necessary measures to ensure that people within its jurisdiction are treated in accordance with international norms and standards. 138. In the opinion of this Commission, the ZANU (PF) is a political party (the ruling party) in Zimbabwe and just like any other party in the country, distinct from the government. It has an independent identity from the government with its own structures and administrative machinery, even though some of the members of the Zimbabwe Government - cabinet ministers, also hold top ranking positions in the party. For example, President Robert Mugabe is the President and First Secretary General of the Party.35 This Commission also holds that the War Veterans Association is a group of ex-combatants of the Zimbabwe liberation struggle. President Mugabe was the Patron during the period under consideration. 139. Given what this Commission will call the "mixed membership", it would appear that there is a very thin line to be drawn between the Government and the ZANU (PF), the Government and War Veterans and between the ZANU (PF) and the War Veterans. There are members of government who are members of the party and members of the party who are war veterans. However thin the line of distinction may seem, it is not the view of the African Commission that the ZANU (PF) and the Zimbabwe Liberation War Veterans Association are structures of the Government or organs of the State. The complainant did not supply the African Commission with documentary evidence to prove this relationship. Even if President Mugabe is Patron of the War Veterans and exercises control over the group, this does not make the war veteran association part of government or State machinery. 140. It must also be noted that during oral submissions by both parties at the 35th Ordinary Session of the African Commission, the Complainant dropped its argument that the ZANU (PF) and the Zimbabwe Liberation War Veterans Association were structures of the government or organs of the State. The Complainant noted in its submission of 26 August 2004 that " the assertion that the Respondent State acquiesced to the gross violations of human rights is based not on agency but a failure to effectively protect its citizens from the harmful conduct of third parties". In the African Commission's view therefore, the Complainant has admitted not only that ZANU (PF) and the War Veterans are not government structures or organs of the State, but is also accepting the State's argument that it had nothing to do with their alleged actions. The Complainant is simply concerned with the fact that the State has a responsibility to effectively protect its citizens from the harmful conduct of third parties, a responsibility, which, according to the Complainant, the Respondent State failed to discharge. It is therefore the view of the African Commission that both ZANU (PF) and the Zimbabwe Liberation War Veterans Association are organisations outside the government or State structures and as such, non-state actors. 17