Covenant, it relates its views to the state concerned and publishes them. The Committee often specifies a particular remedy or action to be taken by the state concerned, either specifically to provide an effective remedy to the complainant or more generally.41 International Covenant on Economic, Social and Cultural Rights According to Art. 16 of the Covenant, enforcement is achieved, at first instance, by states parties submitting reports on measures adopted in pursuit of the aims and objectives of the Covenant. These are delivered to the Secretary-General, who then transmits them to the Economic and Social Council (Art. 16.2). The reports should contain such information as “factors and difficulties affecting the degree of fulfilment of obligations under the present Covenant” (Art. 17.2). The Economic and Social Council may submit reports to the General Assembly that include general recommendations applicable to all states parties in order to meet the aims and objectives of the Covenant (Art. 21). In 1985, the Council created an expert body, the Committee on Economic, Social and Cultural Rights, to assist it in monitoring compliance by states parties with their obligations under the Covenant and in monitoring the level of implementation. States make reports to the Committee every five years.42 European Convention for the Protection of Human Rights and Fundamental Freedoms The Convention established a court (the European Court of Human Rights) at Strasbourg, which may be petitioned by individuals, companies, and non-governmental organizations that claim that their Convention rights have been violated. The Court may award what the Convention calls “just satisfaction”, usually monetary compensation for damage resulting from a violation of the Convention,43 to individuals whose rights have been violated. State compliance with the determinations of the European Court of Human Rights is overseen by the Council of Ministers. In addition, various Convention rights impose obligations on states concerning remedies for human rights violations. Art. 13 states that parties to the Convention have agreed to provide effective domestic remedies for people who claim that their Convention rights have been violated. The European Court of Human Rights has also interpreted certain Convention rights to impose positive obligations, i.e., a state has the duty not merely to refrain from certain actions through official bodies but also to take steps to protect everyone from such actions by private individuals. Hence, where a claim involving a violation of the right to life (Art. 2) is involved, states are required to have effective and independent means of investigating the circumstances of death.44 This is especially relevant in cases of alleged mistreatment or bullying in the armed forces. In addition, the right not to be subject to torture or inhuman or degrading treatment or punishment (Art. 3) imposes on states a positive duty to prevent such acts and to punish those responsible through the legal process. Fundamental rights in European law Finally, the protection of fundamental rights under European Union law should be mentioned. This is a matter of potential importance since 27 OSCE participating States are 41  Shelton, op. cit., note 38, pp. 183-187. 42  Office of the High Commissioner for Human Rights, “Fact Sheet No.16 (Rev.1), The Committee on Economic, Social and Cultural Rights”, <http://www.unhchr.ch/html/menu6/2/fs16.htm>. 43  In some cases, the Court may issue specific measures to remedy the situation complained of beyond ordering monetary compensation, though this is quite rare. See, for example, the case of Broniowski v. Poland, European Court of Human Rights, 22 June 2004, European Human Rights Reports, Vol. 40, p. 21. 44  McCann v. UK, European Court of Human Rights, 27 September 1995, European Human Rights Reports, Vol. 21, 1996, p. 97; Kaya v. Turkey, European Court of Human Rights, 19 February 1998, European Human Rights Reports, Vol. 28, 1998, p. 1; Hugh Jordan v. UK, European Court of Human Rights, 4 May 2001, European Human Rights Reports, Vol. 37, 2001, p. 52. 40 Handbook on Human Rights and Fundamental Freedoms of Armed Forces Personnel