A/HRC/44/43 Preventing and Combating Corruption. How States approach policy coherence when implementing their respective commitments is not always apparent. Both home and host States should do more to incorporate human rights impacts when addressing corporate corruption.59 Similarly, any focus on responsible business conduct and human rights should include corruption-related factors. 25. The OECD Guidelines for Multinational Enterprises are the only multilaterally agreed and comprehensive guidelines for responsible business conduct that Governments have committed to promoting. They include a chapter on human rights, built entirely on the pillar II of the Guiding Principles, and address corruption. Therefore, corruption and business and human rights form part of the same package of responsible business conduct. This applies to all multinational enterprises under the jurisdiction of countries adhering to the Guidelines (including several non-OECD-member countries). The OECD Due Diligence Guidance for Responsible Business Conduct supports the implementation of the Guidelines. The Guidelines present unified due diligence requirements for business on countering corruption and ensuring respect for human rights in line with the Guiding Principles. The main driver of anti-corruption activity at OECD, however, has been the Working Group on Bribery in International Business Transactions. That Working Group monitors the implementation and enforcement of the OECD anti-bribery convention and does not focus on human rights.60 The Convention is open to non-members of OECD. The Convention and the Guidelines have influence beyond OECD members, including through various responsible-business projects. 26. In its guidance, the Working Group on the issue of human rights and transnational corporations and other business enterprises has highlighted that national action plans on business and human rights provide a tool to promote greater coordination and coherence on public policies that relate to business and human rights.61 It has stated that a national action plan is a point of departure and the beginning of a process of national action involving all relevant stakeholders, with the objective of transforming policy into practice.62 In its resolution 26/22, the Human Rights Council noted the important role that such plans could play as a tool for promoting the comprehensive and effective implementation of the Guiding Principles. 27. Given that such plans can serve as a powerful forward-looking instrument that can inspire new regulations and policies,63 they could address both business and human rights and anti-corruption measures. Incorporating both topics into national action plans could lead to more coherent policy frameworks, signal integrated expectations of the private sector and generate programmes to prevent harmful conduct, especially in contexts with both human rights and corruption risks. Many States have dedicated national anticorruption strategies. A first step would be for national action plans to cross-reference links between corruption and business-related human rights abuses.64 For example, Italy, in its contribution, noted that its first national action plan on business and human rights contained several references to combating corruption, as did the revised 2018 version. The National Human Rights Commission of Bangladesh noted that including anti-corruption standards in a national action plan would enable better coordination. 28. Coherent guidance on respecting human rights and addressing corruption assists businesses operating overseas. The cross-government Business Integrity Initiative, initiated by the United Kingdom of Great Britain and Northern Ireland, helps international businesses guard against bribery, corruption and human rights abuses. 65 Support includes online guidance, the Business Integrity Consultancy Service, which provides advice on 59 60 61 62 63 64 65 See A/HRC/35/33 and A/HRC/38/48. See www.oecd.org/corruption/anti-bribery/OECD-Anti-Bribery-Recommendation-ENG.pdf. See www.ohchr.org/Documents/Issues/Business/UNWG_NAPGuidance.pdf. A/74/198, para. 17. Ibid. See https://globalnaps.org/issue/corruption/. See www.gov.uk/government/publications/anti-corruption-newsletter-summer-2019/anti-corruptionnewsletter-summer-2019. 9