73 their retirement,” and they requested the Court to designate Máximo Jesús Atauje Montes to make these calculations; d) As for the reparation of the pecuniary damage, in the brief on requests, arguments and evidence, they requested the Court that, in order to establish the exact amount of the compensation for damages, “it should take into account the accounting expertise that is available to the Court, at the appropriate time.” Subsequently, in their brief with final arguments, they clarified that the purpose of the expert report presented in the public hearing was “to explain the magnitude of the patrimonial damage that had been caused,” and that they did not intend the Court to order the State to reimburse the amounts indicated in this report, but that it should take them as a reference in order to establish compensation for pecuniary damage; e) As regards the compensation for non-pecuniary damage, it requested the Court that “in accordance with the testimonies of Carlos Torres and Guillermo Álvarez, it should determine, in fairness, the amount of the reparation for the suffering endured by the five pensioners and their next ofS kin.” In this respect, they indicated that the alleged victims have endured suffering, anxiety and concerns arising from the lack of financial means to satisfy their needs and those of their families, “as a result of the reduction of their pensions, almost ten years ago, and the subsequent denial of justice for eight years during which they untiringly invested, energy and efforts in order to achieve compliance with the judgments in their favor”; f) The five pensioners expressed their willingness to donate “any amount” ordered by the Court in their favor to the National Human Rights Coordinator so that it can be used to protect the victims of violations of the right to social security and non-compliance with judgments by the State; g) With regard to measures of satisfaction and guarantees of nonrepetition, they requested the Court to order the State to acknowledge publicly its international responsibility “for the reduction in the amounts of the equalized pension to which the five pensioners are entitled, for failure to pay, during these years, the difference between the amount owed and the amounts actually received, and also for denial of justice,” and that it should make a public apology for the occurrence of these facts. It also requested that the State should publish the acknowledgement of responsibility and the apology in two newspapers with wide national circulation; h) As a measure of satisfaction and guarantee of non-repetition, they indicated that the State should conduct an impartial and effective investigation, in order to punish the SBS and MEF officials responsible for the prolonged failure to comply with the judgments. They added that the proceedings filed by the alleged victims are paralyzed; i) As a guarantee of non-repetition, they requested that the Court “should order the State of Peru to establish a Study Group, formed of wellknow academics and international experts in that field from […] ILO, and the Committee on Economic, Social and Cultural Rights.” The Study Group should draw up a report with recommendations on the legislative initiatives or modifications necessary to fully adapt Peru’s legislation on social security to its international obligations;