A/HRC/38/48 Approaches (for example, short-term transactions, working capital or support for bonds). Similarly, export credit agencies should develop useful models of human rights screening and due diligence that relate to transactions that may not clearly fall under the current definition of “project” (for example, the sale of mobile equipment such as ships or communications equipment). 104. States should consider using many of the multilateral forums that exist for export credit agencies to engage in developing good practices and further commitments relating to the Guiding Principles. Such forums include the Berne Union, the International Working Group on Export Credits, the European Union and the BRICS Export Credit Forum. 105. Export credit agencies should focus much more on the issue of enabling access to remedy. That includes developing better practices for evaluating, supporting and incentivizing the quality of the grievance mechanisms of their clients/applicants at the operational level. At the same time, export credit agencies also need to ensure that they have effective complaints mechanisms and that such mechanisms are readily accessible by affected parties, rights holders and communities. That is an area where the OECD Common Approaches are silent. 106. Export credit agencies should review their current transparency and disclosure policies and consider revising them to make more information public. Following the example of the Netherlands, export credit agencies can begin from a presumption that material is made public and then carve out narrow exemptions. There may also be a way to present some data in aggregate form or to redact confidential information but still provide civil society with key facts about both successful applications and those turned down by an export credit agency. 107. States are encouraged to further develop innovative measures to prevent trade in goods that are connected to serious human rights risk in global supply chains. 108. While the present recommendations are focused primarily on States, civil society groups are encouraged to continue their advocacy around issues of human rights, export credits and trade promotion, and to seek greater alignment of State policies and regulations with the Guiding Principles. Similarly, businesses are encouraged to work in partnership with trade promotion entities to develop and disseminate effective guidance on how business respect for human rights can be demonstrated in cross-border trade. 20

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