A/HRC/11/13 page 24 Company level 100. Effective grievance mechanisms are an important part of the corporate responsibility to respect. They complement monitoring or auditing for human rights compliance. They also provide an ongoing channel through which the company gains early warning of problems and disputes and can seek to avoid escalation; many of now emblematic cases of corporate-related human rights abuse started out as far lesser grievances. Moreover, by tracking complaints, companies can identify systemic problems and adapt practices to prevent future harm and disputes. 101. The scale and complexity of dedicated mechanisms will depend on the extent of the companies’ likely impacts. They need not be cumbersome to be effective and they may be partially outsourced or shared with other operations or companies, provided the grievance mechanism principles are met. An increasing number of companies, business associations and business-related organizations are developing grievance mechanisms or related guidance. The Special Representative welcomes the decision by the ICC, IOE and BIAC to pilot these principles with companies in different sectors, and hopes this will generate broader lessons.56 National level 102. National human rights institutions (NHRIs) and the NCPs of States adhering to the OECD Guidelines are potentially important avenues for remedy at the national level. In 2008, the Special Representative contributed to various meetings of national human rights institutions and addressed the annual meeting of NCPs. 103. While the mandates of some NHRIs may currently preclude them from work on business and human rights, for many it has been a question of choice, tradition or capacity. The Special Representative hopes that more NHRIs will reflect on ways they can address alleged human rights abuses involving business. He welcomes the decision of the International Coordinating Committee of NHRIs to establish a working group on business and human rights and looks forward to continued cooperation. 104. NCPs stress the need for operational flexibility that reflects national circumstances. But to ensure the credibility of the system as a whole, this ought to be delimited by minimum performance criteria in line with those set out by the Special Representative. Several NCPs, notably in the United Kingdom and Netherlands, have developed innovative governance structures, transparency measures and mediation capacity that merit attention. Moreover, Governments should consider ways to give more weight to NCP findings against companies. For example, since Governments are obliged to promote the OECD Guidelines under which NCPs operate, a negative finding logically might affect the company’s access to government procurement and guarantees. 56 http://www.reports-and-materials.org/Joint-views-of-IOE-ICC-BIAC-to-Ruggie-Mar2009.pdf.

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