sets out that Frontex considers respect and promotion of fundamental rights to be “unconditional and integral components of effective integrated border management.”76 Indeed, the strategy takes important steps towards accountability: it notes that the Court of Justice of the European Union (CJEU) currently has authority to review “the legality or provide interpretation to guide the acts of the EU Agencies which in turn are obliged to respect fundamental rights in all their activities” and that “Frontex should therefore also take into account the relevant EUCJ case-law in its activities.”77 Likewise, the strategy states that when the EU accedes to the European Convention of Human Rights the European Court of Human Rights will also be able to review the actions of the EU and “Frontex should therefore also take into account the relevant ECtHR case-law in its activities.”78 As well as referring to the obligations under the Charter of Fundamental Rights of the EU, the strategy states, “All human rights instruments adopted by the United Nations and the Council of Europe Conventions as ratified by all the Member States are applicable.” The document emphasizes that Frontex shares responsibility with member states, but distinguishes between member state responsibility for their actions and Frontex’s responsibility for coordinating those actions. Article 13 of the strategy reads: Member States remain primarily responsible for the implementation of the relevant international, EU or national legislation and law enforcement actions undertaken in the context of Frontex coordinated joint operations (JOs) and therefore also for the respect of fundamental rights during these activities. This does not relieve Frontex of its responsibilities as the coordinator and it remains fully accountable for all actions and decisions under its mandate. Frontex must particularly focus on creating the conditions for ensuring compliance with fundamental rights obligations in all its activities.79 76 Ibid., preamble. 77 Ibid.,para. 7. 78 Ibid., para. 6. 79 Ibid. THE EU’S DIRTY HANDS 28