at overthrowing the government or accusing human rights defenders of defending criminals or being criminals themselves. 119. PACE has expressed the concern that “defenders face defamation campaigns aimed at discrediting them or are accused of being unpatriotic, traitors, ‘spies’, or ‘extremists’ in a number of the organization’s member states”.165 Moreover, PACE has called on member states to stop making unfounded accusations of human rights defenders as being “extremists or agents of foreign powers”.166 120. In a number of OSCE participating States, stigmatization and smear campaigns appear to contribute to a wider pattern of delegitimizing human rights defenders who receive funds or perform their work in a professional capacity as being driven primarily by financial gain rather than by motives related to the cause of human rights. Moreover, in some participating States, human rights work is discredited through the adoption of legislation that, for example, portrays human rights defenders who receive foreign funding as ‘foreign agents’.167 Any such laws should be reviewed in consultation with human rights defenders and, if necessary, amended or repealed. 121. It has been reported that human rights defenders or their organizations are tar- geted individually by orchestrated smear campaigns, including through the media, as well as other forms of stigmatization designed to damage their personal reputation or the credibility of their organization. For example, gender stereotypes are regularly used to discredit women human rights defenders.168 As the UN Working Group on the issue of discrimination against women in law and practice has emphasized, women human rights defenders also experience harassment, threats 165  See PACE Resolution 1660 (2009) on the situation of human rights defenders in Council of Europe member states, adopted on 28 April 2009, para. 4. 166  See PACE Resolution 1891 (2012), adopted on 27 June 2012, para. 5.8. 167  In his opinion on Russian NGO legislation, for example, the Council of Europe Commissioner for Human Rights concluded that the continuing use of the term “foreign agent” would lead to further stigmatization of civil society and have a “chilling effect” on the activities of civil society: “[t]he use of the term ‘foreign agent’ (inostranniy agent) is of particular concern to the organisations affected by the implementation of the Law on Foreign Agents, since it has usually been associated in the Russian historical context with the notion of a ‘foreign spy’ and/or a ‘traitor’ and thus carries with it a connotation of ostracism or stigma.” See Opinion of the Commissioner for Human Rights on the legislation of the Russian Federation on non-commercial organisations in light of Council of Europe standards, CommDH(2013)15, 15 July 2013, <https://wcd.coe.int/ViewDoc. jsp?id=2086667>, paras. 57 and 80. Concerning the negative connotation of the term “foreign agent”, see also European Commission for Democracy through Law (Venice Commission) and OSCE Office for Democratic Institutions and Human Rights (OSCE/ODIHR), “Joint Interim Opinion on the Draft Law amending the Law on Non-commercial Organisations and other Legislative Acts of the Kyrgyz Republic”, CDL-AD(2013)030, 16 October 2013, para. 47. 168  In Resolution 68/181, for example, the UNGA expressed deep concern about the impact of historical and structural inequalities that also resulted in violations and the abuse of women human rights defenders and the stigmatization of their work “owing to discriminatory practices and those social norms or patterns that serve to condone violence against women or perpetuate practices involving such violence”, see UN Doc. A/RES/68/181, preamble. Guidelines on the Protection of Human Rights Defenders 63