expression, States have three positive obligations: to prevent, protect, and investigate and criminally punish those responsible.19 The United Nations Plan of Action on the Safety of Journalists and the Issue of Journalists establishes enhanced obligations for States, as follows: (a) the obligation to instruct State security forces to adopt adequate protection mechanisms to avoid violence against those who work in the media; (b) the obligation to investigate, prosecute, and criminally punish those who carry out acts of violence against journalists and media workers; (c) the obligation to protect journalists and media workers who are exposed to a special, real and imminent risk with respect to their fundamental rights; (d) in the event of structural and systematic violence in the country against journalists and media workers, States must establish special protection programs that guarantee the exercise of their journalism activities. 32. Lastly, “generally speaking, the authorities do not connect the crimes committed against journalists to their profession (…). In particular, regarding violence against women journalists, there are no adequate systems for documenting complaints and investigations in Colombia.” 20 Therefore, in order to secure adequate justice for the freedom of expression of women journalists, the State has the obligation to investigate evidence of the participation of State agents in such facts and to implement mechanisms to prosecute crimes against journalists. VI. CONCLUSION 33. In order to guarantee the safety of journalists, the State has the obligations to PREVENT, PROTECT, and SEEK JUSTICE. 21 Such obligations demand intervention from a gender approach. 22 34. The State has a duty to guarantee the exercise of free, independent and plural journalism, which includes the opportunity to do journalism work in safety and, in the case of women journalists, guaranteeing they can engage in their professions free from moral, psychological, and sexual harassment and sexual violence. 19 Amicus curiae of the Universidad de la Sabana. 20 Testimony of Dr. Catalina Botero. United Nations Plan of Action on the Safety of Journalists and the Issue of Impunity. https://en.unesco.org/sites/default/files/un-plan-on-safety-journalists_en.pdf. See specific recommendations at https://digitallibrary.un.org/record/3870659/files/A_HRC_44_52-ES.pdf 21 22 https://www.oas.org/en/iachr/expression/docs/reports/2014_04_22_violence_web.pdf 9