69. Various local agencies and international organizations have pronounced on the context of repression directed against trade unionists in Guatemala during the 1990s. 70. In June 1993, the IACHR issued its Fourth Report on the Human Rights Situation in Guatemala.71 In that report ,the Commission wrote as follows: The existence of vigorous trade union activity in Guatemala show that there is a place for the exercise of public freedoms that allows trade unions to act and exercise their right to freedom of expression, but that space is continually under attack from attempts to restrict it in the form of arbitrary arrests, death threats, attacks on trade unionists' lives, and arbitrary dismissals of trade union leaders.72 71. In its report, the IACHR described some of the concrete acts it became aware of to the detriment of trade unionists, including death threats and various forms of harassment, and even a case similar to that alleged in this instance, which was described by the IACHR as "the kidnapping, torture, and hacking to death of trade union leader Senón Sánchez López" in October 1992. The Commission identified a link between employers' failure to honor workers' rights, the trade union response to that, and the activation of mechanisms to prevent trade unions from exercising that right of response. There were, as the IACHR pointed out, several such mechanisms, including murder.73 72. With that link in mind, the Commission noted the following with regard to maquiladora assembly plants: Reliable studies reveal numerous abuses with respect to the assembly plants' failure to provide decent and legally required working conditions or pay the minimum wage; their use of child labor, compulsory overtime; the lack of sanitation; dismissals of workers' leaders, and so on. Six out of every 10 such employers force personnel to work overtime, with average working hours per week ranging from 55 to 70. Cases have even been documented of workers forced to stay in the factory from Monday through Saturday, without going out, working 80 hours a week.74 73. In 2003, the IACHR wrote in its report on Justice and Social Inclusion: The Challenges of Democracy in Guatemala, the Commission continued to observe attacks on human rights defenders, including trade unionists, as well as the impunity habitually associated with those violations. As the IACHR put it: (...) threats and attacks on human rights defenders in Guatemala are still not punished. The cover up of the act of harassment or aggression to the defender is evident and consists, for example, in disappearing the evidence related to the facts. Impunity in these cases encourages new violations against human rights defenders, which at the same time limits their work.75 74. The United Nations Mission for Verification of Human Rights in Guatemala (MINUGUA) stated in its first annual report, in 1995, that impunity was the greatest obstacle to achieving observance of human rights in Guatemala.76 In its 1998 annual report MINUGUA maintained that there were “problems with 71 IACHR, Fourth Report on the Situation of Human Rights in Guatemala, June 1, 1993. 72 IACHR, Fourth Report on the Situation of Human Rights in Guatemala, June 1, 1993. 73 IACHR, Fourth Report on the Situation of Human Rights in Guatemala, June 1, 1993. 74 IACHR, Fourth Report on the Situation of Human Rights in Guatemala, June 1, 1993. 75 IACHR, Justice and Social Inclusion: The Challenges of Democracy in Guatemala, December 29, 2003, par. 76. 76 Press release "Guatemala UN ascertains impunity for violating human rights”, March 14, 1995. 12