situations are significantly different.54 As the UN Human Rights Committee has stated, the principle of equality sometimes requires states to take affirmative action in order to diminish or eliminate conditions which cause or help to perpetuate discrimination.55 The ICERD also expressly permits special measures for the purpose of securing adequate advancement of certain racial or ethnic groups or individuals requiring such protection.56 Similarly, the FCNM requires State Parties to that treaty to adopt, where necessary, adequate measures in order to promote the effective equality of persons belonging to national minorities in all areas of economic, social, political and cultural life, and that such measures shall not be considered to be an act of discrimination.57 43. Action to protect human rights defenders should be underpinned by compre- hensive anti-discrimination laws and policies that offer effective legal and other protection against discrimination, including to those who experience multiple or intersectional discrimination.58 Measures to strengthen the protection of human rights defenders and create a safe and enabling environment should be reflective of the specific needs of human rights defenders who face discrimination. 44. In particular, every activity to strengthen the protection of human rights defend- ers should be examined for the different impact it may have depending on gender, and for its unintended impact in reinforcing stereotypes and patterns of exclusion. Accordingly, the UNGA has expressed particular concern regarding “systemic and structural discrimination and violence faced by women human rights defenders of all ages”, and has called on states to “take all measures necessary to ensure their protection and to integrate a gender perspective into their efforts to create a safe and enabling environment for the defence of human rights”.59 54  See the judgement of the ECtHR in Thlimmenos v. Greece (2000), para. 44, which states: “The Court has so far considered that the right under Article 14 not to be discriminated against in the enjoyment of the rights guaranteed under the Convention is violated when States treat differently persons in analogous situations without providing an objective and reasonable justification […] However, the Court considers that this is not the only facet of the prohibition of discrimination in Article 14. The right not to be discriminated against in the enjoyment of the rights guaranteed under the Convention is also violated when States without an objective and reasonable justification fail to treat differently persons whose situations are significantly different.” 55  UN Human Rights Committee General Comment No. 18, 1989, para. 10. 56  Article 1(4) ICERD. 57  Article 4 FCNM. 58  The Explanatory Memorandum to Recommendation CM/Rec(2010)5 explains the terms as follows: “Multiple discrimination can be said to occur when a person suffers discrimination based on his or her connection to at least two different protected discrimination grounds, or because of the specific combination of at least two such grounds. The latter situation is often also referred to as intersectional discrimination. An example of that is when a lesbian woman is treated less favourably than a heterosexual woman would be but also less favourably than a gay man.” 59  UNGA Resolution 68/181, December 2013, para. 5. Guidelines on the Protection of Human Rights Defenders 37