A/HRC/44/43 Practices Act in the United States and the Bribery Act in the United Kingdom, as well as in international conventions. The potential for liability leads companies to prevent, detect and respond to corruption across their operations. The anti-bribery approach that some companies follow embeds prevention at governance and decision-making levels to uphold standards of integrity across operations. Data indicate that business action is insufficient to address corruption. For example, enforcement actions under the Foreign Corrupt Practices Act, as well as the Corruption Perceptions Index of Transparency International, repeatedly feature examples of large-scale bribery. 50. Key actors, including OECD and the United Nations Global Compact, have called for a holistic, integrated approach to responsible business conduct. Companies have also done so, through their own codes of conduct. The existing instruments in this area presuppose integrated frameworks. The Ten Principles of the Global Compact emphasize that companies should operate in ways that meet fundamental responsibilities in respecting human rights and countering corruption.92 In its contribution, the Global Compact stated that, as companies faced similar risks from adverse human rights impacts and corruption, it encouraged businesses to identify synergies between human rights and anti-corruption compliance to meet their responsibility to respect human rights in a systematic and structured way, and embed respect for human rights in corporate culture. Despite this, and the similar approach taken by OECD, most businesses do not engage comprehensively in achieving the expected outputs. 51. Despite the expectations set by OECD and the Global Compact, businesses lag behind in the implementation of human rights due diligence processes alongside existing integrity and anti-corruption measures. As the Working Group has previously observed, according to recent human rights benchmarking and rating assessments, the majority of companies covered by the assessments did not demonstrate practices that met the requirements set by the Guiding Principles. This may indicate that risks to workers and communities are not managed adequately despite growing awareness and commitments.93 However, encouraged by benchmarking initiatives, investor pressure, legal developments and trends toward transparency in corporate responsibility, good practices are emerging, for example clear recognition of what the risks to people are, and accurate descriptions of due diligence processes in place to address specific risks. 94 One researcher observed that building a meaningful case for integrity beyond mere compliance was a key focus of some anti-corruption compliance teams, who were focused on future-proofing their companies, enabling them to increase resilience through sustainable business practices.95 The key point is that businesses should strengthen human rights due diligence processes alongside anticorruption compliance efforts. 52. Not many companies are genuinely focusing on such alignment. This suggests that companies’ anti-corruption efforts may not be equipped to capture risks to people, that is, negative impacts on human rights. The Partnering Against Corruption Initiative and the Global Future Council on Transparency and Anti-Corruption of the World Economic Forum are looking at what alignment should encompass by way of creating more resilient models for sustainable business. 53. Notwithstanding the above, companies have adopted good practices to reduce human rights and corruption risks by aligning their implementation of anti-corruption compliance programmes and human rights due diligence processes, including: (a) Incorporating human rights into anti-corruption procedures and ensuring an emphasis, including by senior business leaders, on a corporate culture of integrity; (b) Ensuring that lawyers and managers handling compliance and legal risks are aware of the Guiding Principles; 92 93 94 95 See www.unglobalcompact.org/what-is-gc/mission/principles. A/73/163, para. 25. Ibid., paras. 46–47. See https://fcpablog.com/2020/01/03/compliance-alert-anti-corruption-and-human-rights-efforts-willconverge-in-2020/. 15