Gender, minority groups and culture Women belonging to minority and indigenous groups often find themselves in a particularly vulnerable situation as a result of the multiple forms of discrimination to which they can be exposed.399 Minority and indigenous women are simultaneously victims of discrimination because of their gender and the ethnic or religious group to which they pertain. These different grounds of discrimination ‘intersect and reinforce each other with cumulative adverse consequences for the enjoyment of human rights’.400 As a result, they face ‘double’ unequal treatment, significantly reduced opportunities and severe social exclusion. As Banda and Chinkin point out in their report: ‘[l]ooking at the effects of gender and race combined requires identifying when minority or indigenous women suffer discrimination in different circumstances, of a different kind, or to a different degree to minority and indigenous men, and when minority or indigenous women suffer sex discrimination in different circumstances, of a different kind, or to a different degree than majority women’.401 Multiple discrimination and international practice The UN Development Group Guidelines on Indigenous Peoples’ Issues, for instance, indicate that where data exists, it points to disparities between the indigenous population and society as a whole and confirms that indigenous peoples and, in particular, indigenous women, have less access to health services, adequate housing and education, dispose of lower incomes and have fewer employment and vocational training opportunities.402 In particular, the guidelines highlight that ‘indigenous women [are] worse off than indigenous men and non-indigenous women in terms of poverty levels, access to education, health and economic resources, political participation and access to land, among other issues’.403 More recently, on the occasion of the 50th anniversary of the Discrimination (Employment and Occupation) Convention, 1958 (No. 111), building on the years of experience in monitoring the implementation of the Convention, the CEACR of the ILO emphasized the phenomenon of multiple discrimination.404 Women often face obstacles in access to and retention of employment and stereotyped assumptions on their aspirations and capabilities as well as their suitability for certain jobs, which lead to their segregation in education and training and consequently in the labour market. For women belonging to indigenous and minority groups these difficulties are coupled with, complemented and reinforced by discrimination patterns along ethnic and religious lines. The CEACR noted that women belonging to indigenous and tribal peoples and ethnic minorities as well as female migrant workers are often disproportionately vulnerable to discrimination.405 In its comments on the application of ILO Convention No. 111,406 the CEACR captured this situation on a number of occasions.407 While the CEACR has observed the phenomenon of multiple discrimination against minority and indigenous women from the viewpoint of employment, occupation, professional training and education, the CEDAW has emphasized the broader dimension of it. In its Concluding Observations on Ecuador of 2008, it pointed out that: ‘indigenous women continue to experience double discrimination, based on their sex and ethnic origin, and violence, which constitute an obstacle to their de facto enjoyment of their human rights and full participation in all spheres of life. [..] indigenous women and women of African descent are disproportionally affected by poverty, have lower level of access to higher education, higher school drop-out rates, higher rates of maternal mortality and early pregnancies, higher rates of unemployment and underemployment, lower wages and a lower level of participation in public life than the rest of the population of Ecuador.’ 408 The vulnerability of minority and indigenous women thus manifests itself in a wide range of areas, including scant participation in decision-making and exposure to violence. However, it should be noted that the Convention on the Elimination of All Forms of Discrimination against Women does not refer to the issue of multiple discrimination and only focuses on ‘any distinction, exclusion or restriction made on the basis of sex’.409 A similar approach is found in the ICERD which MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE 41