A/HRC/4/35 page 17 human rights elements.47 Depending on the project, IFC may require impact assessments that include human rights elements and community consultation. Client compliance is subject to review by an ombudsman, who may hear complaints from anyone adversely affected by the social or environmental consequences of an IFC-funded project.48 The IFC standards also have accountability spillover effects, as they are tracked by banks adhering to the Equator Principles, which account for some two thirds of global commercial project lending.49 52. Beyond the intergovernmental system, a new multi-stakeholder form of soft law initiatives is emerging. Most prominent among them are the Voluntary Principles on Security and Human Rights (Voluntary Principles), promoting corporate human rights risk assessments and training of security providers in the extractive sector; the Kimberley Process Certification Scheme (Kimberley) to stem the flow of conflict diamonds; and the Extractive Industries Transparency Initiative (EITI), establishing a degree of revenue transparency in the taxes, royalties and fees companies pay to host Governments. 53. Driven by social pressure, these initiatives seek to close regulatory gaps that contribute to human rights abuses. But they do so in specific operational contexts, not in any overarching manner. Moreover, recognizing that some business and human rights challenges require multi-stakeholder responses, they allocate shared responsibilities and establish mutual accountability mechanisms within complex collaborative networks. These can include any combination of host and home States, corporations, civil society actors, industry associations, international institutions and investors groups. 54. These hybrids seek to enhance the responsibility and accountability of States and corporations alike by means of operational standards and procedures for firms. These often go together with regulatory action by Governments, both supported by transparency mechanisms. Kimberley, for instance, involves a global certification scheme implemented through domestic law. States ensure that the diamonds they trade are from Kimberley-compliant countries by requiring detailed packaging protocols and certification, coupled with chain-of-custody warranties by companies. 55. In these collaborative ventures, there is no external legislative body that sets standards and no separate adjudicative body to assess compliance. Both functions are internalized within the operational entity itself. But without such mechanisms, how can they be judged? 47 Fundamental labour rights, the health and safety of surrounding communities, avoidance of involuntary resettlement, the rights of indigenous peoples, and protection of cultural heritage. 48 Although the IFC standards have been criticized for “not going far enough”, they exceed the human rights requirements of the so-called Common Approaches among the export credit agencies of OECD member States. 49 Critics charge that Equator banks themselves lack transparency in how they implement the principles.