A/HRC/11/13 page 19 down the supply chain a buyer’s responsibility extends depends on what a proper due diligence process reveals about prevailing country and sector conditions, and about potential business partners and their sourcing practices. A growing number of global buyers are finding it necessary to engage in human rights capacity-building with suppliers in order to sustain the relationship. 76. The Special Representative will continue to explore how human rights due diligence might legitimately vary across businesses of different roles and sizes, as he provides a principled elaboration of human rights due diligence applicable to all businesses. Free-standing? 77. Debate continues on how best to integrate human rights policies throughout a company. Some believe that human rights should be folded into existing due diligence processes, while others believe that human rights due diligence needs to be free-standing. 78. An advantage cited for free-standing procedures is that the relevant issues get the attention and professionalization they deserve. But a disadvantage may be that it is not connected to the rest of the company. In contrast, folding human rights due diligence into ongoing processes may put human rights on par with other key issues when managers evaluate potential projects, but the unique attributes of human rights may thereby get diminished. 79. A single model is unlikely to fit all situations. But two principles seem critical. First, companies must recognize that human rights are not merely another topic, but that it demands meaningful engagement with affected parties within and beyond the company. Second, oversight of compliance with a company’s human rights policy must have its own direct line of access to corporate leadership. The Special Representative will draw on lessons from practical experience to inform further conceptual refinement of this issue. Liability 80. Another question that has been raised, including by some corporate general counsel, is whether following these human rights due diligence requirements could increase the potential liability for firms by providing external parties with information they would not otherwise have had to use against the company. 81. This view seems to be more widespread in the United States than elsewhere, perhaps reflecting a more litigious tradition. But the case for it is not self-evident, even in the United States context. Under a variety of corporate governance regulations, companies are required to assess, manage and disclose material risks - as well as to evaluate the effectiveness of their systems for doing so - in order to avoid liability. As we have seen, involvement in human rights violations can be a material risk. Moreover, not knowing is itself a risk, and an unreliable defence. Beyond the legal sphere lie the value of reputation and the cost of operational disruptions. On sheer prudential grounds, therefore, a leading Wall Street law firm concluded