A/HRC/44/43 (c) Ensuring that corruption and human rights risks are considered in employee onboarding systems; (d) Having standard codes of conduct or ethics adopted by the board, and ensuring the inclusion of contractual clauses (including in contracts with intermediaries) incorporating human rights and anti-corruption provisions; (e) auditing; (f) Including human rights and corruption as areas covered in non-financial Building capacity by including human rights in anti-corruption training; (g) Integrating the identification of human rights risk and the identification of anti-corruption risk; (h) Incorporating corruption risks into human rights due diligence by engaging the company’s compliance department; (i) Organizing sectoral peer-learning; (j) Integrating human rights considerations into whistle-blower and reporting mechanisms, including through hotlines and grievance mechanisms; (k) Implementing all applicable anti-corruption and human rights laws and standards during preparatory stages for the Olympics.96 54. However, despite these good practices, challenges to aligned approaches persist. These include sustainability, supply chain and human rights departments on the one hand and legal and compliance departments on the other working independently in silos, focusing on, respectively, human rights and anti-corruption measures. Such a division has resulted in poor communication, diligence fatigue, a lack of shared objectives and challenging auditing processes where red flags were missed; a lack of coordination, sharing of information and collaboration within different parts of a business, for example between geographic offices and headquarters and between different departments; poor informationsharing and knowledge management regarding business and human rights and anticorruption cases and issues; insufficient training, guidance and support on how to implement business and human rights responsibilities and anti-corruption measures alongside each other; and resistance from operations, weary from dealing with multiple interlocutors. 55. Contributors emphasized that there was no one-size-fits-all approach and no concrete trend towards companies developing single integrated compliance or risk frameworks covering both corruption and human rights. Alignment is not the same as integration. As some contributors noted, fully integrating anti-corruption and human rights due diligence could risk watering down core commitments to respect human rights. The goal of human rights due diligence is eliminating risks to people, and such due diligence is a values-driven endeavour. Since responsible business conduct focuses on corruption prevention and respect for human rights, it is key for corporate boards and managers to ensure that both priorities incrementally support a holistic corporate culture and management approach. 56. Contributors acknowledged that company codes of conduct and contractual requirements for suppliers and agents often have an integrated voice, linking anti-bribery obligations to measures respecting human rights. Likewise, other aspects of international regulatory and compliance diligence are integrated. Some sectors that raise concerns, such as the pharmaceutical and extractive sectors, have made headway in addressing corruption and business-related human rights abuses, but not necessarily in an aligned way. For example, they may have separate human rights and corruption working groups and trade associations. Practically speaking, in the anti-corruption context, diligence falls into several categories, including employee diligence, third-party (or transaction-related) diligence, mergers and acquisitions diligence and operational diligence, including anti-corruption risk 96 16 See https://stillmed.olympic.org/media/Document%20Library/OlympicOrg/Documents/Host-CityElections/XXXIII-Olympiad-2024/Host-City-Contract-2024-Principles.pdf.