against them, which is even more serious when the woman is the head of the family; (iv) the risks derived from contact or from family or personal relationships—voluntary, accidental, or presumed—with the members of any of the illegal armed groups that operate in the country or with members of security forces, mainly due to accusations or retaliation carried out a posteriori by opposing illegal groups; (v) the risks derived from belonging to women's social, community or political organizations, or from their leadership and promotion of human rights in areas affected by the armed conflict; (vi) the risk of persecution and murder due to the coercive strategies to control the public and private behavior of the people who form part of the illegal armed groups in vast areas of the national territory; (vii) the risk of the murder or disappearance of their economic provider or the disintegration of their family groups and their material and social support networks; (viii) the risk of being more easily dispossessed of their lands and assets by illegal armed actors, given their historical relationship to property, especially rural land; (ix) the risks derived from the condition of discrimination and heightened vulnerability of indigenous and Afrodescendant women; and (x) the risk of loss or absence of their partner or financial provider during the displacement process […]. 52 46. Regarding the risk of sexual violence, this high court has defined it as “habitual, widespread, systematic, and invisible” in the context of the Colombian armed conflict, 53 noting that within the framework of said conflict, such violence has been a component of the fighting and political strategies carried forth by a variety of actors, thus becoming a weapon of war. 54 This systematic sexual violence against women within the conflict takes various forms, including rape, sexual slavery, and forced prostitution, along with forms of violence that affect reproductive rights, such as forced birth control with intrauterine devices and forced abortions. 55 47. Added to the above is the fact that violence directed against women has been influenced by a “three-pronged process of official and unofficial invisibility; silence on the part of the victims; and impunity for perpetrators,” 56 with it also being overshadowed by the country’s other problems and 52 Cf. Constitutional Court of Colombia, Order 092 of 2008, of April 14, 2008 (evidence file, folio 430). See also, "Access to Justice for women victims of sexual violence," Fifth Follow-up Report on order 092 of 2008 of the Constitutional Court (evidence file, folios 568 and following). 53 Cf. Constitutional Court of Colombia, Order 092 of 2008, of April 14, 2008 (evidence file, folio 434); See also ECOSOC, Commission on Human Rights, Report of the Special Rapporteur on violence against women, its causes and consequences, Mission to Colombia (November 1 to 7, 2001), E/CN.4/2002/83/Add.3, March 11, 2002, para. 42. 54 In this regard, the UN Special Rapporteur on Violence against Women has indicated, referring to violence against women in the context of an armed conflict, that sexual assault is “often experienced as a means of humiliating the opposition” and that “rape is used by both sides as a symbolic act.” Cfr. UN, Commission on Human Rights, 54th period of sessions, Report of the Special Rapporteur on violence against women, its causes and consequences, Ms. Radhika Coomaraswamy, submitted in accordance with Commission resolution 1997/44, Doc. E/CN.4/1998/54, of January 26, 1998, paras. 12 and 13. Likewise, the Colombian Constitutional Court itself has also recognized that, during the armed conflict, sexual violence was used to “retaliate against women who refuse to have sexual relations with members of any of the armed actors or who resist their violence or spontaneous sexual exploitation;” as punishment for breaking the “social codes of conduct imposed de facto by illegal armed groups;” or to “retaliate against, repress, or silence” the activities of women human rights defenders or leaders. Cfr. Constitutional Court of Colombia, Order 092 of 2008, of April 14, 2008 (evidence file, folio 436). Likewise, the National Center for Historical Memory has established that sexual violence, in the context of the armed conflict, “has been part of an array of warlike and political strategies to leverage the interests of armed actors in the context of their campaigns to expand, dominate, and control territory.” Cfr. National Center for Historical Memory, report, “La Palabra y el Silencio: La violencia contra periodistas en Colombia (1977-2015),” November 2015 (evidence file, folio 2331). See also, Report of the Special Rapporteur on violence against women, its causes and consequences, Mission to Colombia (November 1 to 7, 2001), supra, para. 42. Lastly, as witness Catalina Botero indicated in this regard, sexual violence in the Colombian context “was— and continues to be—used as a weapon to silence, to intimidate, and to control territory." Cfr. Statement made before a notary public by Catalina Botero Marino, of March 4, 2021 (evidence file, folio 39934). 55 Cf. Report of the Special Rapporteur on violence against women, its causes and consequences, Mission to Colombia (November 1 to 7, 2001), supra, para. 56. 56 Cf. Constitutional Court of Colombia, Order 092 of 2008, of April 14, 2008 (evidence file, folio 437). 17

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