A/HRC/4/35 page 22 72. How do these companies and other business entities respond to social expectations regarding accountability? Most FG500 firms said they had internal reporting systems to monitor their human rights performance. Three quarters indicated that they also reported externally, but of those fewer than half utilized a third-party medium like the Global Reporting Initiative (GRI). Some form of supply chain monitoring was relatively common. But only one third said they routinely included human rights criteria within their social/environmental impact assessments. The business recognition study generally matched this pattern. 73. Similarly, each of the collective initiatives required some form of reporting; the ICMM utilizes the GRI. Most had remediation requirements for non-compliant participants, and four prescribed grievance mechanisms for employees or community members. Five extended human rights requirements to supply chain practices, with accountability mechanisms ranging from periodic audits to certifying individual factories or global brands. 74. In short, leading business players recognize human rights and adopt means to ensure basic accountability. Yet even among the leaders, certain weaknesses of voluntarism are evident. Companies do not necessarily recognize those rights on which they may have the greatest impact. And while the rights they do recognize typically draw on international instruments, the language is rarely identical. Some interpretations are so elastic that the standards lose meaning, making it difficult for the company itself, let alone the public, to assess performance against commitments. 75. There are also variations in the rights companies emphasize that seem unrelated to expected sectoral differences, but which appear instead to reflect the political culture of company home countries. For example, European-based firms are most likely to adopt a comprehensive rights agenda, including social and economic rights, with American firms tending to recognize a narrower spectrum of rights and rights holders. 76. Where self-regulation remains most challenged, however, is in its accountability provisions. The number, diversity, and uptake of instruments have grown significantly. But they also pose serious issues about the meaning of accountability and how it is established. Only three can be touched on here: human rights impact assessments (HRIAs); materiality; and assurance. 77. For businesses with large physical or societal footprints, accountability should begin with assessments of what their human rights impact will be. This would permit companies and affected communities to find ways of avoiding negative impacts from the start. Several SRI funds strongly promote HRIAs, coupled with community engagement and dialogue. However, relatively few firms conduct these assessments routinely and only a handful seem ever to have done a fully-fledged HRIA, in contrast to including selected human rights criteria in broader social/environmental assessments.60 And apparently only one company, BP, has ever made public even a summary of an HRIA. No single measure would yield more immediate results in the human rights performance of firms than conducting such assessments where appropriate. 60 The difference and its significance are described in a companion report, A/HRC/4/74.