47 the Convention on the Rights of the Child;205 Article 1 of the European Social Charter206 and Article 15 of the African Charter on Human and Peoples’ Rights.207 146. Consequently, when analyzing the meaning and scope of Article 26 of the Convention in this case, the Court will take into account, in light of the general rules of interpretation established in Article 29(b), (c) and (d) of this instrument,208 the aforementioned protection of job security 209 as applicable to the specific case. 147. In this regard, the Committee on Economic, Social and Cultural Rights, in its General Comment No. 18 on the right to work, indicated that this included “the right not to be deprived of work unfairly.”210 It has also indicated that “[v]iolations of the obligation to protect follow from the failure of States parties to take all necessary measures to safeguard persons within their jurisdiction from infringements of the right to work by third parties,” which include “failure to protect workers against unlawful dismissal.”211 148. For example, Convention 158 of the International Labour Organization (ILO) on termination of employment (1982),212 establishes that the right to work includes the lawfulness of termination in its article 4213 but stipulates, in particular, the need to provide “a valid reason for such termination”214 as well as the right to effective legal remedies in case of an unjustifiable termination. Likewise, ILO Recommendation No. 143 215 on workers’ representatives requires that Article 32. […] 2. States Parties shall take legislative, administrative, social and educational measures to ensure the implementation of the present article. To this end, and having regard to the relevant provisions of other international instruments, States Parties shall in particular: a) (a) Provide for a minimum age or minimum ages for admission to employment; (b) Provide for appropriate regulation of the hours and conditions of employment; (c) Provide for appropriate penalties or other sanctions to ensure the effective enforcement of the present article. 205 Article 1. The right to work. With a view to ensuring the effective exercise of the right to work, the Contracting Parties undertake: 1. To accept as one of their primary aims and responsibilities the achievement and maintenance of as high and stable a level of employment as possible, with a view to the attainment of full employment; 2. To protect effectively the right of the worker to earn his living in an occupation freely entered upon; 3. To establish or maintain free employment services for all workers; 4. To provide or promote appropriate vocational guidance, training and rehabilitation. 206 Article 15. Every individual shall have the right to work under equitable and satisfactory conditions, and shall receive equal pay for equal work. 207 Cf. Compulsory Membership of an Association Prescribed by Law for the Practice of Journalism (arts. 13 and 29 American Convention on Human Rights), OC-5/85, supra, paras. 51 and 52; Juridical Status and Rights of Undocumented Migrants, OC-18/2003 of September 17, 2003. Series A No. 18, para. 156. Regarding the scope of labor rights, in order to identify a group of rights that have a crucial importance for migrant workers, the Court applied the pro persona principle, indicating that if there are several instruments that regulate the same situation, the domestic or international instrument that best protects the worker must be preferred. 208 Cf. Case of Baena Ricardo et al. v. Panama. Merits, reparations and costs. Judgment of February 2, 2001. Series C No. 72, para. 134. 209 UN. Committee on Economic, Social and Cultural Rights, General Comment No. 18: The right to work, UN Doc. E/C.12/GC/18, November 24, 2005. 210 211 UN. Committee on Economic, Social and Cultural Rights, General Comment No.18: The right to work, supra. ILO. Convention No. 158 on termination of employment, November 23, 1985. It should be pointed out that, as the Peruvian State indicate, Convention No. 158 has not been ratified by Peru. 212 Article 4 of Convention No. 158. The employment of a worker shall not be terminated unless there is a valid reason for such termination connected with the capacity or conduct of the worker or based on the operational requirements of the undertaking, establishment or service. 214 Article 5 of Convention No. 158. The following, inter alia, shall not constitute valid reasons for termination: (a) union membership or participation in union activities outside working hours or, with the consent of the employer, within working hours; (b) seeking office as, or acting or having acted in the capacity of, a workers' representative; (c) the filing of a complaint or the participation in proceedings against an employer involving alleged violation of laws or regulations or recourse to competent administrative authorities;[…]. 213 Cf. ILO, Recommendation on Workers’ Representatives, 1971 (No. 143), Recommendation on protection and facilities that should be afforded to workers’ representatives. Fifty-sixth Session of the ILO General Conference; date adopted June 23, 1971. Paragraph 5: Workers' representatives in the undertaking should enjoy effective protection against any act prejudicial to them, including dismissal, based on their status or activities as a workers' representative or 215