A/HRC/8/5 page 18 59. The Special Representative’s research and consultations indicate that a basic human rights due diligence process should include the following.41 Policies 60. Companies need to adopt a human rights policy. Broad aspirational language may be used to describe respect for human rights, but more detailed guidance in specific functional areas is necessary to give those commitments meaning. Impact assessments 61. Many corporate human rights issues arise because companies fail to consider the potential implications of their activities before they begin. Companies must take proactive steps to understand how existing and proposed activities may affect human rights. The scale of human rights impact assessments will depend on the industry and national and local context.42 While these assessments can be linked with other processes like risk assessments or environmental and social impact assessments, they should include explicit references to internationally recognized human rights. Based on the information uncovered, companies should refine their plans to address and avoid potential negative human rights impacts on an ongoing basis. Integration 62. The integration of human rights policies throughout a company may be the biggest challenge in fulfilling the corporate responsibility to respect. As is true for States, human rights considerations are often isolated within a company. That can lead to inconsistent or contradictory actions: product developers may not consider human rights implications; sales or procurement teams may not know the risks of entering into relationships with certain parties; and company lobbying may contradict commitments to human rights. Leadership from the top is essential to embed respect for human rights throughout a company, as is training to ensure consistency, as well as capacity to respond appropriately when unforeseen situations arise.43 Tracking performance 63. Monitoring and auditing processes permit a company to track ongoing developments. The procedures may vary across sectors and even among company departments, but regular updates of human rights impact and performance are crucial. Tracking generates information 41 The principles are the same for all companies, although specific procedures may differ in small and medium-sized enterprises. 42 43 The Special Representative submitted a separate report on this subject in 2007 (A/HRC/4/74). BLIHR, OHCHR, and the Global Compact, A Guide for Integrating Human Rights into Business Management, available at www.ohchr.org/Documents/Publications/ GuideHRBusinessen.pdf.