A/HRC/21/43 concern the usefulness of the Principles as setting out the basic parameters for a self2 regulatory mechanism such as the Code and Charter. 22. The Working Group suggested specific areas in which the Charter could be strengthened. For example, it should require field audits. In addition, the third-party grievance mechanism established by the Charter should be revised to address the substance of third-party complaints (as envisaged in the Code), rather than focusing only on the procedural compliance of member companies. Lastly, the draft Charter contains provisions that permit companies to refuse to share information with monitoring mechanisms owing to contractual provisions or the potential for parallel legal proceedings. While the Working Group recognizes the reasoning behind such provisions, it believes that they present significant loopholes that could prevent the effective operation of Charter mechanisms and that the inclusion of such provisions reflects the inherent limitations of a self-regulatory mechanism, which can never replace accountability through the law. 23. The Working Group welcomed the opportunity to participate in the public consultation on the draft Charter and hopes that its comments will assist the Temporary Steering Committee in strengthening the draft Charter and producing a final document that lives up to the commitments made by the signatory companies to the Code. IV. Research into national regulation of private military and security companies 24. The Working Group believes that it would be useful to study and identify legislative approaches regarding the activities of private military and security companies and to assess the effectiveness of national legislation in protecting human rights. Such a study would inform the Working Group’s efforts to demonstrate the need for a legally binding international instrument. In addition, it would assist in identifying best practices and may inform future projects to develop guidance for Member States seeking to regulate private military and security companies. 25. The Working Group is conducting this work in phases. First, it is analysing national legislation that is easily accessible to develop preliminary conclusions on the models used by States. An example of this approach is the analysis of the national legislation of three countries set out below. Second, the Working Group has initiated a survey to collect national legislation pertaining to private military and security companies. It has requested Member States to provide information in this respect and will supplement the information collected with additional research. Some of this research will be conducted in collaboration with civil society partners. 26. The Working Group plans to analyse national legislation on a region-by-region basis. It is anticipated that the first regional analysis will be included as part of the report of the Working Group to the Human Rights Council at its twenty-fourth session, in 2013. 2 Examples of civil society statements are available from www.escrnet.org/usr_doc/Joint_Statement_draftGPs_wendorsements-final-2.pdf and http://fian.org/news/pressreleases/CSOs-respond-to-ruggies-guiding-principles-regarding-human-rights-and-transnationalcorporations/pdf. 7