3.2 –Protection of women against violence 537. Violence against women, girls and children in Togo is multifaceted. It includes conjugal violence, sexual harassment, rape, forced marriage, levirate, sororate, female genital mutilation (FGM), food prohibitions, widowhood rites, confinement in convents, etc. 538. According to the study on gender-based violence, 41% of women in union were victims of physical violence, 91% of psycho-moral violence, 34% of economic violence, 33% of sexual violence and 20% of institutionalized violence. (DGGPF, 2010). 539. Combating all these forms of violence is a major concern of the Togolese Government and organizations active in the area of gender equality and their elimination is considered a top priority. The rate of FGMs dropped from 12% in 1996 to 2% in 2012. 3.2.1 - Physical integrity and dignity, including sexual violence, trafficking in women and medical and scientific experiments (Articles 3 & 4) 540. Protecting the physical integrity and dignity of women remains one of the most disturbing aspects in the fight against violence against women and girls. Article 12 of the Constitution states that "every human being shall have the right to the physical, intellectual, moral and cultural development of their person" and "the State shall be obliged to guarantee the physical integrity and the life and safety of all persons living on the national territory" (Article 13 of the Constitution). Chapter IV of the new Criminal Code punishes "attacks on the physical integrity of the person" without distinction of sex. Indeed, "Anyone who subjects an individual to cruel and inhuman punishment or treatment shall be punished by a penalty of ranging between ten (10) years and twenty (20) years of criminal imprisonment and a fine of between twentyfive million (25,000,000) and one hundred million (100,000,000) CFA francs (Article 202). Similarly, "Anyone who subjects an individual to degrading treatment shall be punishable by five (5) to ten (10) years of imprisonment and a fine of ranging between five million (5,000,000) to twenty-five million (25,000,000) CFA francs (Article 204). 541. Women are protected because of their vulnerability in the same Code. Barbarism is criminalized in Article 209 and sexual offences, such as rape and female genital mutilation, are punishable and highlighted under Articles 211 to 222. The Code is also sufficiently clear on trafficking in persons and the smuggling of migrants by land, sea and air (Articles 317 to 334) and incriminates perpetrators. 153