A/HRC/36/56 natural resources without the consent of the concerned indigenous peoples. In arriving at its decision, the Court made reference to articles 26-28 of the Declaration, indicating that, although it was not binding, the Declaration was relevant for the purposes of interpreting the Constitution of Belize as it related to indigenous rights. D. United Nations agencies and other multilateral actors 44. OHCHR continues to engage with indigenous peoples to support implementation of the Declaration, through its field offices. For example, the OHCHR office in Guatemala, along with the United Nations Voluntary Fund for Victims of Torture, provided support to indigenous women in a landmark 2016 case in which a Guatemalan court recognized as a crime against humanity the sexual violence committed against indigenous women of the village of Sepur Zarco during the internal armed conflict in the 1980s. Recognition of indigenous peoples’ rights and their inclusion and participation in the review of the United Nations Development Assistance Framework and/or workplans by all country offices, in line with the Declaration/ILO Convention No. 169, would ensure a more robust approach to indigenous issues across the United Nations system. 45. As well as the Expert Mechanism, the other two United Nations mechanisms supporting indigenous peoples — the Permanent Forum and the Special Rapporteur on the rights of indigenous peoples — provide important guidance and recommendations to all stakeholders in the implementation of the Declaration. The coordination between them is a good example of a coherent approach to the implementation of indigenous rights. This includes the participation of the Special Rapporteur in the sessions of the mechanisms, allowing for parallel meetings with indigenous peoples’ representatives and others, joint statements and coordination meetings. Even closer collaboration will be required as the Expert Mechanism develops its new mandate. Partnerships with national human rights institutions, which have become increasingly important in helping to achieve the aims of the Declaration, should be further encouraged in this context. 46. In 2014, Member States reaffirmed their support for the Declaration at the World Conference on Indigenous Peoples, the outcome document of which 45 contains many commitments, two of which are of particular significance. One commitment culminated in the General Assembly consultation process aiming to enhance the participation of indigenous peoples’ representatives in meetings of United Nations bodies on issues affecting them. Those consultations are ongoing and have so far produced a draft resolution that is currently before the General Assembly, and the appointment of indigenous cofacilitators in the Conference. However, additional work is required to ensure all bodies and organizations throughout the United Nations system enable the participation of indigenous peoples’ own representatives and institutions in relevant meetings on issues affecting them. 47. The second significant commitment made by States through the United Nations relates to the preparation of national action plans to implement the Declaration. While some States have developed sector-specific national strategies relating to indigenous peoples, 46 to date only a small number of States, including El Salvador and Paraguay, appear to be developing specific action plans for indigenous peoples. It is relevant to note that the Paraguayan national action plan also makes reference to the protection of indigenous peoples in voluntary isolation, an issue on which OHCHR published guidelines in 2012 reflecting Declaration rights. It is difficult to see how States can comprehensively realize the full set of Declaration rights without an action plan that covers all the articles in the Declaration, or without taking into account the findings and recommendations of international human rights mechanisms, or without the participation of all sectors of indigenous people’s society. 48. A further element to come out of the World Conference on Indigenous Peoples was a request that the United Nations develop a system-wide action plan on indigenous peoples to develop a coherent approach to achieving the ends of the Declaration. In 2011, ILO, 45 46 12 General Assembly resolution 69/2, annex. Australia, Finland, New Zealand and the Philippines.