A/HRC/14/27 be supplemented by criteria that include respect for international human rights standards.16 In the United States, all contractors doing significant business with the Federal Government must certify that they have compliance programmes rooted in ethical and legally compliant cultures, based on those required in the Federal Sentencing Guidelines.17 32. In short, the State’s role as an economic actor is a key — but underutilized — leverage point in promoting corporate human rights awareness and preventing abuses. C. Fostering rights-respecting corporate cultures 33. The State duty to protect extends well beyond its role as economic actor. Most States have adopted measures and established institutions relevant to business and human rights, including labour standards, workplace non-discrimination, health and safety and consumer protection. However, States have been slow to address the more systemic challenge of fostering rights-respecting corporate cultures and practices. Four policy tools and their current usage are discussed here: CSR policies, reporting requirements, directors’ duties and legal provisions specifically recognizing the concept of “corporate culture”. 34. Numerous governments have adopted CSR guidelines or policies. To cite two recent examples, India has issued guidelines for companies to protect workers’ rights, implement respect for human rights and avoid complicity in human rights abuses,18 while a CSR white paper by Norway guides companies on relevant international human rights standards, suggests resources for addressing human rights-related dilemmas and recommends that companies adopt the framework’s due diligence process.19 35. Nevertheless, on the whole, relatively few national CSR policies or guidelines explicitly refer to international human rights standards. They may highlight general principles or initiatives that include human rights elements, notably the OECD Guidelines and the Global Compact, but without further indicating what companies should do operationally. Other policies are vaguer still, merely asking companies to consider social and environmental “concerns”, without explaining what that may entail in practice. To merit the term “policy”, even voluntary approaches by States should indicate expected outcomes, advise on appropriate methods and help disseminate best practices. The United Nations framework’s “corporate responsibility to respect” pillar can provide guidance in this regard. 36. Encouraging or requiring companies to report on human rights policies and impacts is a second key policy tool. It enables shareholders and other stakeholders to better engage with businesses, assess risk and compare performance within and across industries. Moreover, it helps companies to integrate human rights as core business concerns, supporting their responsibility to respect human rights. 37. Governmental guidance or policies on CSR reporting, including on human rights, varies widely. Examples in State-owned enterprises from China, Netherlands and Sweden were already mentioned. In Denmark, all companies above a certain size must report whether they have CSR policies.20 In Malaysia, annual reports of listed companies must 16 17 18 19 20 8 See, for reference, http://www.agentschapnl.nl/sustainableprocurement/criteria_development/ index.asp. United States Federal Register, vol. 73, No. 219, 12 November 2008. Available from http://www.mca.gov.in/Ministry/latestnews/CSR_Voluntary_Guidelines_24dec2009. pdf. Available from http://www.regjeringen.no/en/dep/ud/Documents/Propositions-and-reports/Reportsto-the-Storting/2008-2009/report-no-10-2008-2009-to-the-storting.html?id=565907. Act amending the Danish Financial Statements Act, 2008. GE.10-12629