In November 2008, the Governing Body of the ILO decided to set up a Commission of Inquiry, in accordance with article 26, paragraph 4, of the ILO Constitution, to examine the complaints filed by a number of delegates to the Conference concerning the observance by the Government of Zimbabwe of Conventions Nos 87 and 98 on freedom of association. As recalled by the Director-General of the ILO at the inaugural session of the Commission, this was the first occasion on which a Commission of Inquiry had arisen out of simultaneous complaints from Workers’ and Employers’ delegates to the Conference. The complaints examined by the Commission of Inquiry referred in particular to serious allegations of violations of basic civil liberties, including the quasi-systematic arrest, detention, harassment and intimidation of trade union leaders and members for the exercise of legitimate trade union activities.