prosecute and punish the authors of those crimes […]”88 and “establish a safe and enabling environment for defenders to act without threats, harassment, intimidation or violence.”89 This is based on the understanding that defenders cannot properly defend environmental rights if they cannot exercise their own rights of access to information, freedom of expression, assembly and peaceful association, guarantees of non-discrimination and participation in decision-making.90 76. For its part, the United Nations Human Rights Council has recognized the importance of the work carried out by human rights defenders, including those involved in environmental issues, to ensure that States comply with their obligations under the Paris Agreement and the implementation of the 2030 Agenda for Sustainable Development. Consequently, it has emphasized the duty to guarantee them “a safe and enabling environment, so that they are able to act free from threat, restriction and insecurity.”91 77. Similarly, Article 9 of the Escazú Agreement establishes the obligation of the States Party to guarantee “a safe and enabling environment” so that human rights defenders working on environmental issues “can act free from threat, restrictions and insecurity.” It requires States to take “adequate and effective measures to recognize, protect and promote” all the rights of defenders, including their rights to life, personal integrity, freedom of opinion and expression. The general principles of the Agreement also establish that each party shall ensure that the rights recognized therein are freely exercised (paragraph 2) and shall guarantee an enabling environment for the work of persons, associations, organizations or groups that promote environmental protection, by recognizing and protecting them (paragraph 6). In particular, the Escazú Agreement takes into consideration the 2030 Agenda for Sustainable Development and the Sustainable Development Goals (SDG), reaffirming the commitment to achieve sustainable development, in a balanced and integrated manner, in its three dimensions: economic, social and environmental. It also notes that the outcome document of the 2012 United Nations Conference on Sustainable Development, entitled “The Future We Want,” recognizes that democracy, good governance and the rule of law are essential for sustainable development.92 78. The Court considers that respecting and guaranteeing the rights of human rights defenders in environmental matters, in addition to being a commitment acquired by the States party to the American Convention, insofar as they are persons under their jurisdiction, is of special importance because they perform work that is “fundamental to the strengthening of democracy and the rule of law.”93 79. This Court has recognized that, given the importance of environmental work, the free and full exercise of this right imposes on the States the duty to create legal and factual 88 Cf. United Nations, Human Rights Council: Right to a clean, healthy and sustainable environment: the nontoxic environment. Report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment. David Boyd. Doc. A/HRC/49/53, January 12, 2022, para. 49, lit. g. 89 Cf. United Nations, Human Rights Council, Report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment, John Knox. Doc. A/HRC/37/59, January 24, 2018, framework principle 4, para. 11. 90 Cf. United Nations, Report of the Special Rapporteur on the situation of Human Rights Defenders, Michel Forst, supra, para. 93. 91 Cf. United Nations, Human Rights Council, Recognizing the contribution of environmental human rights defenders to the enjoyment of human rights, environmental protection and sustainable development. Doc. A/HRC/40/L.22/Rev.1, March 20, 2019. 92 Cf. Regional Agreement on Access to Information, Public Participation and Access to Justice in Environmental Matters in Latin America and the Caribbean (Escazú Agreement), entry into force on April 22, 2021, preamble. 93 Cf. Case of Valle Jaramillo et al. v. Colombia. Merits, reparations and costs. Judgment of November 27, 2008. Series C. 192, para. 87, and Case of Human Rights Defender et al. v. Guatemala, supra, para. 128. 25