A/HRC/32/39 to include such issues, provided there is a recognized basis. Moreover, the Guiding Principles on Business and Human Rights highlight that there are strong policy reasons for home States to set out clearly the expectation that businesses respect human rights abroad, especially when the State itself is involved in or supports those businesses. The reasons include ensuring predictability for business enterprises by providing coherent and consistent messages, and preserving the State’s own reputation.46 While the extraterritorial scope of a prominent national example, the Alien Tort Statute in the United States, has recently been limited, there are a number of other potential avenues, such as in the European Union, that allow for extraterritorial claims to be pursued against corporations for human rights abuses.47 4. Internal accountability mechanisms 117. As part of the due diligence aspect of the Guiding Principles on Business and Human Rights, companies are encouraged to set up internal grievance mechanisms, also referred to in some instances as “operational-level” or “project-level” grievance mechanisms. The mechanisms are usually set up to allow those that are affected by the actions of the company to bring allegations of non-compliance with internal policies and procedures to the attention of the company. Several of the voluntary initiatives, including the International Code of Conduct for Private Security Service Providers, also require companies to set up internal grievance mechanisms to monitor compliance with the principles of the initiatives, considered to be external unless incorporated into those of the company.48 Notwithstanding the potential of internal grievance mechanisms to offer another course of redress to victims of corporate human rights abuse, the functioning of those mechanisms has met with great scepticism in the ranks of civil society. 118. Most internal grievance mechanisms currently require claimants to sign a legal waiver that keeps victims from pursuing further legal action. 49 While the use of such grievance mechanisms has produced some successes in particular circumstances, human rights abuses of certain magnitudes, including violations of the right to life, cannot be adequately addressed through an internal grievance mechanism, and in such cases legal waivers can represent a deliberate impediment to accountability. IV. Conclusions 119. The use of force by private security providers is not uncommon, and can be a necessary element to some of the services they provide. However, the unregulated or improper use of force by such providers can severely jeopardize the protection of the right to life. Where the use of force by private security providers is regulated under the domestic laws and regulations of States that specifically concern private security, 46 47 48 49 20 John F. Kennedy School of Government, Harvard University, 2010). Available from www.hks.harvard.edu/m-rcbg/CSRI/publications/workingpaper_59_zerk.pdf. See Guiding Principles on Business and Human Rights, principle 2. J. Kirshner, “A call for the EU to assume jurisdiction over extraterritorial corporate human rights abuses”, Northwestern Journal of International Human Rights, vol. 13, No. 1 (2015), pp. 1-26. See International Code of Conduct for Private Security Service Providers, article 66. See “Rape victims must sign away rights to get remedy from Barrick”, MiningWatch (30 January 2013). Available from http://miningwatch.ca/news/2013/1/30/rape-victims-must-sign-away-rightsget-remedy-barrick. See also K. McVeigh, “Canada mining firm compensates Papua New Guinea women after alleged rapes”, Guardian, 3 April 2015. Available from www.theguardian.com/world/2015/apr/03/canada-barrick-gold-mining-compensates-papua-newguinea-women-rape.