A/HRC/38/48 occupational health and safety situations. In the 2012 recommendation members were asked to consider the issue of human rights, with the aim of reviewing how project-related human rights impacts might be further addressed in future. There were, however, no specific recommendations on human rights due diligence. 55. In 2016, the OECD Council approved a revised version of the Common Approaches. In that document, there is an explicit statement to the effect that export credit agencies should now screen all applications covered by the Common Approaches, according to whether or not there might be a strong likelihood of severe project-related human rights impacts occurring. 45 Participating export credit agencies should then assess the potential environmental and/or social risks in applications relating to all existing operations for which their share is equal to or above SDR 10 million and all existing operations and projects, irrespective of their share, where screening has identified a strong likelihood of severe project-related human rights impacts occurring. 56. In screening an application, export credit agencies will then place the project into category A, B or C, which imply a requirement for varying levels of environmental and social review, including environmental and social impact assessments. In addition, where screening has identified a strong likelihood of severe project-related human rights impacts occurring, the environmental and social review of a project may need to be complemented by specific human rights due diligence. 57. A footnote to the 2016 recommendation provides examples of severe project-related impacts. For example, impacts that are particularly grave in nature (threats to life, child or forced labour and human trafficking), widespread in scope (large-scale resettlement and working conditions across a sector), cannot be remediated (torture, loss of health and destruction of the land of indigenous peoples) or are related to the operating context of the project in question (conflict and post-conflict situations). 58. Specific methods for human rights due diligence are left to the discretion of individual export credit agencies. Moreover, the due diligence approach described above is only applicable to applications covered by the Common Approaches and therefore excludes transactions, such as short-term credit under two years, working capital, support for bonds and transactions that may be considered outside the current definition of “project”, such as mobile equipment (for example, ships) and communications equipment. The 2016 recommendation allows for projects backed by an export credit agency to be benchmarked against the World Bank environmental and social safeguard policies or the International Finance Corporation (IFC) Environmental and Social Performance Standards, depending on the financial structure of the transactions. Some export credit agencies have decided to benchmark all projects against the IFC Performance Standards, but again practice is variable. 59. For export credit agencies, the OECD Guidelines should also serve as a key tool alongside the Guiding Principles. The Guidelines state that the ownership structure of a multinational enterprise (whether public or private) does not change their applicability. The Guidelines, which incorporate a human rights chapter aligned with the Guiding Principles, require export credit agencies, which are business entities themselves, to engage in appropriate human rights due diligence with respect to their business relationships and to the extent that they are representatives of the State or public entities, to use their leverage to require their business partners and clients to do the same. 60. A recent decision by the Dutch National Contact Point clarifies the status of export credit agencies. In June 2015, the national contact point system received a complaint alleging that Dutch export credit agency, Atradius DSB had failed to comply with the OECD Guidelines in the context of its financing of a dredging project in north-eastern Brazil, which had resulted in severe human rights and environmental impacts. The complaint against Atradius stated that it had failed to ensure that the Guiding Principles and the IFC Performance Standards had been effectively applied to the project. In its initial assessment, accepting the complaint of 3 December 2015, the Dutch National Contact Point 45 12 Para. 6.