A/HRC/30/35 resolution of issues that arise from alleged non-observance of the Guidelines (so called specific instances mechanism). 51 In dealing with specific instances, which are not legal cases, national contact points must make an initial assessment to determine if the issues raised merit further examination, assist in resolving the instances through offering good offices, and make the results of the procedure publicly available. Despite the value of this grievance mechanism, which is accessible to any interested party, the national contact point system has been criticized by civil society on multiple counts and specific recommendations have been provided to strengthen it. 52 Business compliance with other guidelines, for example the Dhaka Principles for Migration with Dignity that relate to reducing exploitation from the moment of the recruitment process is critical to reducing the incidence of forced labour and other contemporary forms of slavery at all levels of supply chains.53 E. Business and stakeholder initiatives to address contemporary forms of slavery in supply chains 46. Global brands and other transnational corporations operating complex supply chains that span multiple jurisdictions have increasingly adopted voluntary codes of conduct to address contemporary forms of slavery in their operations, as well as those of their suppliers, prompted mainly by reputational risk. The voluntary codes cover a wide variety of issues, from social and environmental to human rights and anti-corruption. Policies that clearly prohibit forced labour are now commonplace in codes across companies of different sizes and operating in different regions and sectors. A key recent innovation is the development of policies that address recruitment and hiring in labour supply chains by banning private employment or recruitment agencies supplying workers to facilities in their supply chains from charging recruitment fees to those workers.54 47. Despite their important role in complementing the normative framework, voluntary codes of conduct are often bald statements without any independent monitoring mechanisms and leave numerous gaps in protection if they do not apply to all entities, especially informal sector and home-based suppliers and subcontractors. However, an increasing number of steps are being taken to implement voluntary codes, involving a diverse set of strategies, typically starting with some form of compliance assessment conducted at workplace level in businesses’ supply chains. These are commonly called “social audits” and frequently address other standards in addition to human rights issues, depending on the codes upon which they are based. 48. While businesses continue to rely on social audits as a key element of their human rights due diligence programmes and to assess their own facilities and those of their business partners, many believe that auditing has had a limited impact on identifying and eliminating contemporary forms of slavery from supply chains. New strategies are therefore required that move beyond auditing and include proactive independent investigations and robust independent verification, which incorporate consultations with workers with due 51 52 53 54 14 To date, approximately 300 instances have been addressed by national contact points, covering a range of issues, including human rights, employment and industrial relations. See http://mneguidelines.oecd.org/database/. See, for example, OECD Watch, Remedy Remains Rare – An analysis of 15 years of NCP cases and their contribution to improve access to remedy for victims of corporate misconduct (2015) (http://oecdwatch.org/publications-en/Publication_4201). See also, for example, the ILO Fair Recruitment Initiative and the International Organization for Migration initiative on ethical recruitment. For example, the Electronics Industry Citizenship Coalition has adopted a “no fees” policy for its members.