A/HRC/4/99 page 16 Discussion 53. Participants discussed initiatives and tools that could strengthen human rights protection and the implementation of voluntary standards, such as accountability and monitoring mechanisms. Specific actions by financial institutions were suggested, including ex ante assessments of their investments; ongoing independent monitoring of the human rights impact of their investments; and means of compliance and redress where investments do not uphold human rights standards. Investigatory and sanctioning powers on the part of ombudsmen or monitoring units within a company were considered important, for example in reconciling community claims that damage occurred because of a company’s presence with company claims that the damage pre-dated them, particularly in the absence of baseline information. Reference was made to the Extractive Industries Review of the World Bank Group. Although the human rights recommendations were not accepted by the Bank, it was suggested that the Bank’s extractive industries clients should be required to adopt and demonstrate compliance with human rights standards. 54. Reporting and monitoring requirements were also discussed. It was suggested that the reason the Equator Principles do not have a secretariat or public help desk is because no bank wants to be responsible for decisions by other banks; therefore the “teeth” in the Principles are in the annual reporting requirements. Some NGOs considered the mechanisms of the Principles insufficient with respect to accountability. Emphasizing the importance of indicators to measure performance, the Global Reporting Initiative (GRI) was recommended as a good starting point for companies wishing to report on their performance. The GRI arose from an intensive multi-stakeholder process of identifying how organizations could measure their performance with respect to all human rights. It was suggested that if an organization is reporting to that level of detail on human rights, it is likely to be working towards better human rights performance. 55. A number of participants cited the lack of human rights expertise in financial institutions and the need for outside monitoring and assessments with regard to human rights. Some questioned whether a normative framework would compensate for that lack of expertise, while others noted that such a framework would be subject to interpretation. 56. Human rights impact assessments (HRIAs) were discussed as a potential point of convergence. Reference was made to the forthcoming IFC HRIA tool, which outlines elements similar to the steps of an Environmental Social Impact Assessment (ESIA) but integrates the scope of the review with country risks and context analysis. The IFC tool is to be flexible, although some participants wished to see a comprehensive HRIA as a mandatory inclusion in an action plan or contractual obligation. It was suggested that a commitment to undertake HRIAs could be seen as refining current commitments to undertaking ESIAs. One question raised was whether ESIAs and labour audits can address human rights issues, or whether there should be a complete assessment package under a human rights label. 57. The sector was urged not to start from scratch to develop frameworks and tools, but rather to work with recognized international standards, referring to the previous discussion on the danger of translating and thereby lowering standards (see section II above). There was a need to ensure that corporate initiatives would add value and not detract from what is already in existence. Reassurance was given that initiatives would not detract but rather try to decant that information to create mechanisms for financial institutions to implement in their own way.