A/HRC/4/37 page 13 43. The Special Representative has acted on cases of violence and threats against journalists who have been highlighting the issue of land rights and natural resources in their work. In November 2006, the Special Representative sent a communication to the Government of Russia concerning the alleged attack on a journalist active in covering the issue of land rights in the context of the seizure of farmland. The journalist was allegedly attacked while attending a meeting on this issue. 44. The work of environmental activists is often carried out in close connection with issues of land rights and natural resources. Additionally it has close links, inter alia, to the rights to health, food and water. This issue has been addressed through several communications and in many of the reports of the Special Representative in relation to her official country visits. Following her visit to Kyrgyzstan in 2001, the Special Representative expressed concern at the plight of defenders who had denounced the dumping of nuclear waste and its impact on the environment (see E/CN.4/2002/106/Add.1). 45. According to the statistics of communications sent by the Special Representative, the second most vulnerable group when it comes to the danger of being killed because of their activities in the defence of human rights, are defenders working on land rights and natural resources. The Special Representative has sent communications on at least 35 defenders who have been allegedly killed for this reason since the establishment of the mandate. In the Philippines alone, more than 14 defenders working on issues of land rights and agrarian reform have reportedly been killed during 2006. 46. Defenders working on land rights often organize themselves in the form of social movements. These are usually broad grassroots-based movements with a more horizontal organizational structure than for instance most NGOs. These movements and the defenders who are actively involved in those movements have faced several specific challenges. Two that should be mentioned include accusations of not being properly registered and therefore deemed illegal, whereas the reason behind the non-registration often is that the movements do not have the organizational structures that are needed to enable registration with the authorities, such as a permanent headquarters or a secretariat. Another challenge continues to be that defenders engaged in social movements are accused of “forming criminal gangs” and the like. 47. In October 2006, the Special Representative sent a communication to the Government of Brazil concerning a case where a defender working with the Landless Workers’ Movement (MST) was arrested and allegedly accused of “forming a criminal gang” and “inciting crime”. Concerns were expressed that the defender had been arrested and detained because of his activities in defence of workers’ ESCR. In March 2005, the Special Representative sent a communication, to the same Government, regarding a defender who had been killed, allegedly as a direct result of her work on defending the rights of rural workers and on land reforms in Brazil. 2. Labour rights, including trade union activities 48. Article 6 of ICESCR provides that States parties “recognize the right to work, which includes the right of everyone to the opportunity to gain his living by work which he freely chooses or accepts, and will take appropriate steps to safeguard this right”. The Covenant further deals with the right of everyone to “the enjoyment of just and favourable conditions of