A/HRC/28/73 retaliation, discrimination or any other arbitrary action as a consequence of their legitimate activities in promoting and protecting human rights. 45. Journalists reporting on cases of corruption or promoting human rights as part of their work play a crucial role in the dissemination of information, in awareness-raising, and in the realization of human rights and the fight against corruption. They often discover grievances and bring them to the attention of the public. The information that they provide is an essential precondition for transparency and responsibility. In its established case law, the European Court of Human Rights has emphasized the function of journalists as a “public watchdog”.29 Journalists frequently come under pressure because of their reporting. They may be prosecuted, defamed, harassed or even attacked. States are obliged to guarantee freedom of expression but also any other human rights that may be violated by means of threats or attacks against journalists. 46. Whistle-blowers’ actions lead to the public disclosure of grievances in administrations or enterprises, and can contribute to the process of discovering and combating grievances in the institutions concerned. Whistle-blowing can be a valuable element in the fight against corruption in both public and private entities. Although a number of elements need to be examined about the behaviour of whistle-blowers,30 they can play an important role as insiders who bring incriminating facts to the knowledge of the public. The State is under an obligation to guarantee the right to freedom of expression also to whistle-blowers. This is reflected in the recommendation of the Council of Europe Committee of Ministers on the protection of whistle-blowers, which was adopted on 30 April 2014.31 The Committee of Ministers recommends that member States have in place a normative, institutional and judicial framework to protect individuals who, in the context of their work-based relationship, report or disclose information on threats or harm to the public interest. VII. Recommendations by the Advisory Committee 47. In its resolution, the Human Rights Council requested the Advisory Committee to make recommendations on how the Council and its subsidiary bodies should consider the issue of the negative impact of corruption on the enjoyment of human rights. The resulting report makes substantive as well as procedural recommendations. 48. It is largely accepted that there is a need to link anti-corruption measures with the realization and protection of human rights. What is missing at this stage, however, is strategies to translate the substantive linkage into concrete measures. It seems difficult to develop such strategies or concrete measures in an abstract manner. It seems more useful to identify good and best practices, from which to derive more general guidelines. Such best practices and guidelines would have to be communicated to national experts in an appropriate manner. Information-sharing, discussion and training could be considered, as ways of communicating with national experts. One possibility could be to develop standards on the independence and the modalities of 29 30 31 14 See, for example, European Court of Human Rights, 27 March 1996 (GC), Goodwin v. the United Kingdom, No. 17488/90, §§ 39, 46. See, for example, European Court of Human Rights, 21 July 2011, Heinisch v. Germany, No. 28274/08, §§ 65 et seq. Council of Europe, recommendation of the Committee of Ministers to member States on the protection of whistle-blowers, CM/Rec(2014)7, adopted on 30 April 2014.