65 disproportionate impact on women for various risks relating to gender identified as causes of 307 displacement. 285. In terms of the American Convention, displacement also generates the obligation to provide special treatment in favor of those affected and to adopt positive measures to reverse its effects, 308 including vis-à-vis acts and practices of individual third parties, such as has already been established (see supra, IV C.2). 286. As has already been pointed out (see supra, IV C.1), the Guiding Principles for Internal Displacement of 1998 are of particular relevance when defining the content and scope of Article 22 of the 309 Convention in the context of internal displacement, and the rules on displacement contained in Protocol II to the Geneva Conventions of 1949 prove to be especially useful. Specifically Article 17 of Protocol II prohibits ordering the displacement of the civilian population for reasons related to the conflict, unless the security of the civilians involved or imperative military reasons so demand. And in this last case, "all possible measures" should be taken "in order that the civilian population may be received under satisfactory conditions of shelter, hygiene, health, safety and nutrition." In this regard, the Constitutional Court of Colombia had already considered in 1995 that, "in the case of Colombia, furthermore, the application of these rules by the parties in the conflict is particularly imperative and important, since the armed conflict raging in the country has gravely affected the civilian population, as shown, for example, 310 by the alarming data on the forced displacement of individuals". 287. The Commission also recalls that the Constitutional Court has emphasized that to confront the situation of internal displacement, which presents one of the greatest problems caused by the conflict, Colombia has adopted a series of measures at the legislative, administrative and judicial levels, including numerous laws, decrees and documents of the National Council for Economic and Social Policy, and presidential resolutions and directives. Among these measures Law No. 387 of July 18, 1997 should be mentioned, which defines the concept of displacement and grants a special legal status to individuals in this situation. In turn, a large variety of public policies have been developed in relation to the problem of displacement, including production programs, links with the private sector and various aid programs. However, the Constitutional Court of Colombia itself declared "the existence of an unconstitutional state of affairs in the situation of the displaced population, due to the lack of coincidence between the seriousness of the violation of the rights recognized in the Constitution and developed by law, on the one hand, and the resources effectively available to ensure the proper enjoyment of such rights and the institutional capacity to 311 implement the appropriate constitutional and legal orders, on the other". In particular, it determined that despite the efforts made by various State entities to mitigate the problems faced by the displaced population and the important progress achieved, it has proved impossible to protect completely the rights of the displaced population, and to offset the serious worsening in their 307 Annex 92. Constitutional Court of Colombia, Order 092 de 2008, First Resolution in the Judgment. See IACHR Annual Report 2009, Follow-up Report Violence and Discrimination against Women in the Armed Conflict in Colombia, para. 29. Corte Constitucional, Auto 092 de 2008, Punto Resolutivo Primero. En: http://www.corteconstitucional.gov.co/relatoria/Autos/2008/A09208.htm. 308 I/A Court H.R. Case of the Ituango Massacres. Judgment of July 1, 2006. Series C No. 148, para. 210; I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C No. 134, para. 179. 309 Cf. Annex 91. UN Guiding Principles on Internal Displacement, E/CN.4/1998/53/Add.2 of February 11, 1998. See:http://www.un-documents.net/gpid.htm See also, I/A Court H.R. Case of the Moiwana Community, June 15, 2005. Series C No. 124, paras. 113 to 120 and Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C No. 134, para. 171. 310 Cf. Annex 93. Constitutional Court of Colombia. Judgment C-225/95 of May 18, 1995, para. 33. At: http://www.corteconstitucional.gov.co/relatoria/1995/c-225-95.htm. See I/A Court H.R. Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C No. 134, para. 172. 311 Cf. Constitutional Court Judgment T-025/04 of January 22, 2004. I/A Court H.R. Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C No. 134, para. 182.