A/HRC/38/48 provisions on external action, such as consolidating democracy and respect for human rights, when establishing, developing and implementing their national export credit systems and when carrying out their supervision of officially supported export credit activities.56 D. Export credit agencies and access to remedy 78. Current National Action Plans do not include discussions of the ways in which export credit agencies address and enable access to remedy by rights holders who are harmed in connection with a project or transaction funded or supported by an export credit agency. As a result, civil society groups have recommended that export credit agencies make it easier for rights holders to know about and access relevant complaint mechanisms.57 There are several possible options. One would be to have a grievance or complaint mechanism at the export credit agency itself and a second would be to require clients who receive export credit to have an effective grievance mechanism, as outlined in Guiding Principle 31. Finally, export credit agencies should use their screening, assessment, support and leverage roles to strengthen their client-level mechanisms and outcomes for people. 79. In 2011, the Global Alliance of National Human Rights Institutions submitted comments when OECD first revised its common approaches to address the Guiding Principles. At that time, the Global Alliance called for OECD to include explicit requirements regarding access to remedy for company-related human rights abuses, including through the provision of grievance mechanisms at the project level and at the national or export credit agency level that would be accessible to individuals and communities affected by projects. 58 Although the 2016 revision of the Common Approaches does request that export credit agencies consider measures to prevent, minimize, mitigate or remedy potential adverse environmental and social impacts, it is silent on the issue of complaints and grievance mechanisms. The issue of how export credit agencies can use their leverage to enable effective remedies has not been actively explored to date and deserves significant attention. E. Relationship between the human rights record of a company and future support by the State 80. The Common Approaches specify that export credit agencies “should where appropriate … consider any statements or reports made publicly available by their National Contact Points (NCPs) after a specific instance procedure under the OECD Guidelines for Multinational Enterprises”.59 States that have committed to imposing trade and investmentrelated consequences for businesses refusing to participate in the national contact point process include Canada, Germany and the Netherlands. 81. For example, Canada has adopted an integrated approach to economic diplomacy as part of its enhanced corporate responsibility strategy for the extractive sector, which was launched in 2014. A key component of that approach is making government support in foreign markets conditional on a company’s good faith participation in the two voluntary dispute resolution mechanisms, namely the Office of the Extractive Sector Corporate Social Responsibility Counsellor and Canada’s national contact point. In 2015, that approach led to the withdrawal of Canadian trade commissioner services from China Gold International 56 57 58 59 16 Regulation 1233/2011 of the European Parliament and of the Council of 16 November 2011. See Finance and Trade Watch, and CEE Bankwatch Network “ECAs Go to Market”. The authors recommend that each export credit agency needs to have an independent complaints mechanism with clearly defined procedures and that they formulate and adopt information disclosure and public participation measures. See www.business-humanrights.org/sites/default/files/media/documents/icc-submission-to-oecdexport-credits-dec-2011.pdf. OECD Council recommendation on common approaches (2016), para. 16.