A/HRC/4/99 page 12 “materiality” must be viewed more broadly than “material to financial performance” if disclosure is to capture the true risks to stakeholders. The Principles for Responsible Investment are a very important step forward, but present two broader concerns: first, the human rights obligations of investors should not be limited by fiduciary duty, as they represent obligations to individuals other than shareholders; second, an exclusive focus on shareholder value may limit the ability of investors to address the most difficult human rights issues. 39. Andreas Missbach (Steering Committee member, BankTrack, and Private Finance Programme, Berne Declaration), stressed that financial institutions have special responsibility with regard to human rights, in view of the strategic role that financing plays for their clients. Banks can be complicit by ignoring human rights violations committed by their clients while providing financial assistance for their activities. It was submitted that the Equator Principles are not the solution, as they do not specifically address human rights issues and apply only to project finance, which is less than 5 per cent of capital raised through commercial lending and investment banking. Mr. Missbach gave examples of the human rights impact of the financing of mines, dams and arms trading. Banks should be urged to make their human rights policies more detailed, and to determine their levels of influence according to the various types of financial products and services they offer, and their relationships with clients. In many instances, operations that violate human rights cannot proceed without the support of financial institutions. It was suggested that the Special Representative could discuss the role of banks in his final report and call for a more comprehensive and transparent approach to human rights responsibilities in the banking sector. 40. David Allwood (Business Principles Adviser, Export Credits Guarantee Department (ECGD), United Kingdom) said that the Government of the United Kingdom considers that human rights are State obligations that do not fall to non-State actors. It is, however, the responsibility of States to ensure that non-State actors, including business, respect human rights. ECAs do not usually have direct contact with a project, but only with their national exporters and banks. They generally lack leverage, as a decision to withhold support from a particular export would rarely result in the overseas project to which that export was destined being changed; it would only result in that exporter losing the business to another exporter. Nevertheless, ECGD takes some actions to provide assurance that human rights are being addressed. Mr. Allwood explained that as part of its “Case Impact Analysis Process”,7 ECGD identifies what human rights treaties and ILO conventions have been ratified by the host country where the overseas project is located. ECGD then considers the details of the specific project and whether or not human rights abuses might be present. On this basis, ECGD decides whether further enquiries are necessary. 41. Ivo Knoepfel (Managing Director, onValues Ltd., speaking on behalf of the United Nations Global Compact) presented two private sector-led initiatives developed in collaboration with the United Nations: the Principles for Responsible Investment (PRI); and the “Who Cares Wins” (WCW) Initiative. The PRI provide a general framework for asset owners and investment managers to give appropriate consideration to environmental, social, and corporate governance (ESG) issues. The initiative goes back to 2005 when the 7 See www.ecgd.gov.uk.