CEDAW/C/89/D/170/2021 concerning the author’s forced sterilizations began in 2016 and therefore cannot be considered to be unduly delayed. 4.5 The State party adds that it is necessary for persons who consider themselves aggrieved to file a complaint, 14 in order to be included in investigation No. 14-2016 and/or investigation No. 59-2019. Gloria Basilio Huamán and Elena Rojas Caballero, however, have not yet filed a complaint, 15 despite having the opportunity to do so. 4.6 The State party argues that the communication is unfounded because the Programme on Reproductive Health and Family Planning was intended not only for women but for the general public, that voluntary surgical contraception was carried out on both men and women, and that the birth control policy was not intended to harm people, but rather the opposite; the State party adds that the Programme was not aimed at a specific population group and did not apply exclusively to women, much less Indigenous women, women of limited means or women from rural areas, so the alleged events are not related to discrimination against women. 4.7 Regarding the alleged violations of article 2 of the Convention, the State party argues that equality and protection against discrimination against women are guaranteed under article 2 (2) of the Constitution of 1993. The Programme on Reproductive Health and Family Planning sought to uphold the right to reproductive health for the entire population, reduce barriers to health services for traditionally excluded groups and promote responsible parenthood, allowing both m en and women to decide on the number of children. The Programme was established to address problems such as high maternal and perinatal mortality, inequality in women’s health, reproductive risks in adolescents, maternal and perinatal risks due to sexually transmitted diseases, and morbidity and mortality due to preventable gynaecological pathologies. The State party argues that the Programme does not in itself constitute a discriminatory regulation and that the authors did not provide sufficient informatio n to demonstrate that the sterilizations or their consequences were discriminatory. 4.8 The State party argues that measures exist to ensure the free, prior, full and informed consent of women in sexual and reproductive health procedures and adds that, under the Programme, personnel were trained and all forms of pressure, coercion, violence and manipulation were prohibited. 16 Moreover, in cases of alleged forced sterilizations, the Office of the Inspector General of the Ministry of Health initiated administrative and judicial proceedings. 4.9 In addition, the State party indicates that, on the basis of the information provided by the authors, it cannot be verified that they in fact underwent surgery under the Programme or that they did not consent to the sterilizations. Nevertheless, various criminal investigations and proceedings, in which three of the authors are included as having allegedly been affected by crimes of serious injury, are under way. 4.10 In 2015, the Ministry of Justice and Human Rights declared that the provision of support for victims of forced sterilizations was of national interest, undertaking to provide free legal assistance services in coordination with the Registry of Victims of Forced Sterilization, and that, through their inclusion in the Registry, the authors could access subsidies and financing, in addition to medical coverage. 4.11 In relation to article 3 of the Convention, the State party affirms that various legislative and administrative measures have been adopted to promote equal rights __________________ 14 15 16 24-19966 Organic Law on the Office of the Public Prosecutor, art. 11. The State party cites Cecilia Kell v. Canada, 19/2008, para. 4.4.; B.J. v. Germany, 1/2003, para. 8; and N.F.S. v. United Kingdom, 10/2005, para. 7. Technical standard on family planning, of 31 August 2016. 9/19