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commitments and human rights risk assessments into company decision-making; and tracking as well as reporting performance.

But merely having a set of components in place provides no guarantee that the system will work. Therefore, I am also developing guidance for their implementation. One example is that companies must understand that the responsibility to respect human rights is not a one-time transactional activity, but is ongoing and dynamic. Another is for companies to accept that, because human rights concern affected individuals and communities, managing human rights risks needs to involve meaningful engagement and dialogue with them. And a third is that, because a main purpose of human rights due diligence is enabling companies to demonstrate that they respect rights, a measure of transparency and accessibility to stakeholders will be required.

Grievance Mechanisms

Let me turn next to the subject of grievance mechanisms. State-based judicial and non-judicial mechanisms should form the foundation of a system of remedy for corporate-related human rights abuse. But company-level grievance mechanisms can serve two important functions.

First, they can provide a necessary feedback loop directly from those who may be negatively impacted by company activities, enabling them to raise concerns early and before they escalate. This can serve as an early warning mechanism for companies and is an essential part of their on-going due diligence to be sure they are respecting human rights.

Moreover, where complaints in fact do raise genuine harms, such mechanisms can then play an important role in enabling early remediation. Companies cannot by definition be respecting human rights unless they address their harms.

In the realm of workers’ rights, the ideal scenario is that there be genuine freedom of association; legitimate and trusted unions; and good union- management processes available to handle individual or collective grievances.

But we know that that is far from the reality in many places. While the full implementation of all workers’ rights—including freedom of association— must remain the objective, if that is not immediately possible then interim measures to mitigate harms become a priority.

However, this requires some understanding of what makes for an effective grievance mechanism. Slapping a complaints box on a wall and, in


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