89. Thus, the rights recognized in the American Convention not only entail obligations of a negative nature, but also require that the State adopt all appropriate measures to guarantee them (that is, obligations of a positive nature). 191 The duty covers all legal, political, and administrative measures that promote the protection of human rights and ensure that any violations of them are effectively considered and addressed as a violation of the law that, as such, can lead to punishment of the perpetrators, as well as an obligation to provide comprehensive reparations to victims for the harm caused. 192 90. Additionally, in cases of violence against women, along with the general obligation established in the American Convention, States have specific obligations under the Convention of Belém do Pará that cast light into areas traditionally considered private or where the State did not intervene. 193 This regional treaty specifically aimed at combating violence against women gives a broad definition of what violence against women is in its articles 1 and 2. 194 In addition, the Convention of Belém do Pará itself, in its article 2, includes kidnapping as one of the types of conduct included under the concept of violence against women. Additionally, in Article 7, it establishes that States have a duty to prevent, punish, and eradicate violence against women, specifying and complimenting the State’s compliance obligations for rights recognized in the American Convention, such as those set forth in Articles 4 and 5. 195 In this regard, the Court has established that States must adopt comprehensive measures to act with due diligence in cases of violence against women. Specifically, they must have an appropriate legal framework for protection that is enforced effectively, and prevention policies and practices that allow effective measures to be taken in response to the respective complaints. 196 The prevention strategy should also be comprehensive; in other words, it should prevent the risk factors and, at the same time, strengthen the institutions that can provide an effective response in cases of violence against women. 197 91. The Court highlights that, in connection with the particular risk faced by women journalists, international and regional organizations have concluded that when adopting measures to protect journalists, States must apply a strongly differentiated approach that takes into account gender Cf. Case of Velásquez Rodríguez v. Honduras. Merits, supra, paras. 165 and 166, and Case of Lopez Soto et al. v. Venezuela, supra, para. 129. 191 Cf. Case of López Soto et al. v. Venezuela, supra, para. 129, and Case of the Indigenous Communities of the Lhaka Honhat (Our Land) Association v. Argentina, supra, para. 207. 192 Cf. Case of López Soto et al. v. Venezuela. Merits, Reparations, and Costs. Judgment of September 26, 2018. Series C No. 362, para. 131. 193 194 Article 1 establishes that “For the purposes of this Convention, violence against women shall be understood as any act or conduct, based on gender, which causes death or physical, sexual or psychological harm or suffering to women, whether in the public or the private sphere.” Likewise, Article 2 provides as follows: Violence against women shall be understood to include physical, sexual and psychological violence: a. that occurs within the family or domestic unit or within any other interpersonal relationship, whether or not the perpetrator shares or has shared the same residence with the woman, including, among others, rape, battery and sexual abuse; b. that occurs in the community and is perpetrated by any person, including, among others, rape, sexual abuse, torture, trafficking in persons, forced prostitution, kidnapping and sexual harassment in the workplace, as well as in educational institutions, health facilities or any other place; and c. that is perpetrated or condoned by the state or its agents regardless of where it occurs. Cf. Case of Penal Miguel Castro Castro v. Peru. Merits, Reparations, and Costs. Judgment of November 25, 2006. Series C No. 160, para. 346, and Case of Women Victims of Sexual Torture in Atenco v. Mexico. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 28, 2018. Series C No. 371, para. 180. 195 Cf. Case of González et al. (“Cotton Field”) v. Mexico, supra, para. 258, and Case of Guzmán Albarracín et al v. Ecuador. Merits, Reparations, and Costs. Judgment of June 24, 2020. Series C No. 405, para. 113. 196 197 Cf. Case of González et al. (“Cotton Field”) v. Mexico, supra, para. 258, and Case of López Soto et al. v. Venezuela, supra, para. 131. 35