83. In the specific case of gender-based violence against women that affects female journalists, the Office of the Special Rapporteur of the IACHR has stated that the general obligations of prevention, protection, and the pursuit of justice arising from the obligation to ensure the safety of all journalists in general “are complemented and enhanced” by the obligations derived from the Convention of Belém do Pará. 178 Under Article 7(a) of that Convention, the States must “refrain from engaging in any act or practice of violence against women and to ensure that their authorities, officials, personnel, agents, and institutions act in conformity with this obligation.” Clause (b) of the same article requires the States to apply due diligence to prevent, investigate and impose penalties for violence against women. 84. The Office of the Special Rapporteur has underscored that fulfilling all these obligations involves incorporating a gender perspective to ensure that women journalists are adequately protected and can exercise their right to freedom of expression without undue restrictions. Similarly, the United Nations Plan of Action on the Safety of Journalists and the Issue of Impunity reaffirms the importance of giving to these policies and strategies “a gender-sensitive approach.” 179 To this end, processes and protocols must explicitly recognize that sexual violence and other forms of gender-based violence are specific risk factors to which women journalists are exposed and which deserve specialized approaches. 3. Considerations on violence and rape in light of the American Convention, the IACPPT, and the Convention of Belém do Pará 85. Both the Inter-American Court and the Inter-American Commission have pointed out that in cases of violence against women, the duty to act with due diligence acquires a special and strict connotation “in response to the fact or the mere possibility of their vulnerability in the presence of acts that actually or potentially involve gender-based violence or could result in this type of violence.” 180 86. The Court has previously considered that sexual violence involves acts of a sexual nature, committed against a person without their consent, and that in addition to the physical invasion of the human body, they may include acts which do not involve penetration or even any physical contact. 181 In particular, rape constitutes a paradigmatic form of violence against women, and its consequences go far beyond the victim herself. 182 87. Similarly, following the case law and standards prevailing in both International Criminal Law and Comparative Criminal Law, the Inter-American Court has held that: (…) rape does not necessarily entail non-consensual vaginal sex, as it was traditionally deemed. Rape should also be understood as acts of vaginal or anal penetration, without the consent of the victim, using other parts of the perpetrator’s body or objects, as well as oral penetration by the male organ. 183 In this regard, the Court clarifies that, in order for an act to be considered rape, it is sufficient that penetration, however slight, occurs, as described above. 184 In addition, it must I/A Court H.R., Case of Fernández Ortega et al. v. Mexico. Preliminary Objection, Merits, Reparations and Costs. Judgment of August 30, 2010. Series C, No. 215. Para. 193. 179 UNESCO. Plan of Action. Principles. 180 I/A Court H.R. Case of Veliz Franco et al. v. Guatemala. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 19, 2014. Series C, No. 277, para. 134. See also: IACHR, Report No. 53/13, Case 12.777, Claudina Isabel Velásquez Paiz et al. Merits. Guatemala, November 4, 2013, para. 88. 181 I/A Court H.R. Case of Rosendo Cantú et al. v. Mexico, Preliminary Objection, Merits, Reparation and Costs. Judgment of August 31, 2010. Series C, No. 216. Para. 109. Citing. Cfr. I/A Court H.R. Case of the Miguel Castro Castro Prison v. Peru. Merits, Reparations and Costs. Judgment of November 25, 2006. Series C, No. 160, para. 306. See also International Criminal Tribunal for Rwanda, Case of Prosecutor v. Jean-Paul Akayesu. Judgment of September 2, 1998. Case No. ICTR-96-4-T, para. 688. 182 I/A Court H.R. Case of Rosendo Cantú et al. v. Mexico, Preliminary Objection, Merits, Reparation and Costs. Judgment of August 31, 2010. Series C, No. 216. Para. 109. 183 I/A Court H.R. Case of J. v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 27, 2013. Series C, No. 275, Para. 359. Citing Cfr. I/A Court H.R. Case of the Miguel Castro Castro Prison v. Peru. Merits, Reparation and Costs, supra, para. 310. 184 I/A Court H.R. Case of J. v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 27, 2013. Series C, No. 275, Para. 359, citing. Cfr. International Criminal Tribunal for the Former Yugoslavia. Prosecutor v. Anto Furundzija. Judgment of December 10, 1998, Case No. IT-95-17/1-T, para. 185; International Criminal Tribunal for the Former Yugoslavia. Prosecutor v. Kunarac et al. Judgment of February 2, 2001, Case No. IT-96-23-T and IT-96-23/1-T, para. 437 and 438; International Criminal Tribunal for the Former Yugoslavia. Prosecutor v. Kunarac 178 22