The submission is guided by the organization’s work over many years in a number of ICC situation countries, and analysis we have undertaken of complementarity and cooperation in relation to several situations. The submission is divided into the following sections: Broad observations; The ‘Two-Track’ approach; Public Reporting; ‘Unwillingness’ and Recommendations. An Annex to the submission contains a joint submission co-signed by Amnesty International, with 41 other NGOs titled: ‘Joint NGO Comments on the “[Draft] Policy on Complementarity and Cooperation (September 2023)”’. The comments call for increased transparency to the OTP’s work on complementarity and cooperation, and urge the OTP to commit to regular, detailed, situation-specific public reporting.