A/HRC/44/32/Add.1 relevant.34 Further, mechanisms should adopt a gender perspective in order to understand and address the structural, sociocultural and economic barriers that may prevent women from participating in grievance processes on an equal basis with men. 37. Non-State-based grievance mechanisms vary greatly in terms of their proximity to the business activities they address. The extent to which a mechanism must be independent from relevant business activities in order to be legitimate will depend on that mechanism’s mandate and objectives. Various structural, institutional, administrative and resourcing issues may need to be addressed to ensure that the mechanism is able to discharge its functions fairly (7.5 and 7.6). Independence from the relevant business activities and/or enterprises is particularly important for mechanisms that make use of adjudication (as opposed to dialoguebased methods). 35 Strategies for a mechanism to enhance independence can include transparent hiring processes and appropriate reporting lines, control over a predictable budget, autonomy over policies and procedures, the ability to accept and handle grievances independently of management and the use of an independent, multi-stakeholder advisory panel, that is gender-balanced and properly representative of anticipated user groups and interests. Strategies for addressing conflicts of interest include open and competitive recruitment; restrictions on movements of personnel from the mechanism to relevant business operations (and vice versa); rotation of personnel; declaring and responding to conflicts of interest in specific cases; and delegation of dispute resolution and decision-making to legitimate, independent third-party mechanisms in appropriate cases. 38. Mechanisms should have suitably qualified personnel (7.7) who can discharge their responsibilities in a manner that fosters stakeholder trust (7.8). “Suitably qualified” is context-dependent but could mean (depending on the role in question) a knowledge of human rights and the corporate responsibility to respect human rights, expertise with respect to assessing and responding to risks of retaliation, experience with trauma counselling, and mediation and language skills. Mechanisms should invest in appropriate training to ensure that personnel keep up to date with relevant standards and best practices. 3. Accessibility 39. Policy objective 8 sets out suggestions as to practical steps that can be taken to improve accessibility of non-State-based grievance mechanisms. 40. As part of raising awareness of its existence and procedures (8.1), the mechanism may need to inform stakeholders as to what their rights are and the role of the mechanism in helping to realise them. Any outreach (or other training) needs to be based on a proper appreciation of the structural, sociocultural and economic barriers that may exist to seeking remedies for business-related human rights harm, especially in settings where human rights abuses may have become entrenched. 41. Effective awareness-raising activities will vary depending on the type of mechanism and context. However, many mechanisms have drawn attention to the importance and usefulness, in various contexts, of face-to-face engagement (e.g. meetings and discussion groups); leaflets; prominently-displayed notices (offline and online); social media; and education sessions delivered in a culturally- and gender-sensitive manner, and by people to whom rights holders can readily relate (e.g. peers, union representatives or community members). 42. The accessibility of mechanisms is often marred by overly restrictive or complicated eligibility criteria (8.2). Although mechanisms may need to balance a number of competing considerations relating to eligibility, criteria should always be properly disseminated36 and consistently applied. Time limits for accessing the mechanism should be flexible enough to take account of the length of time that abuses may take to become apparent, or for the rights holders to become aware of the mechanism, as well as other barriers that may be faced by 34 35 36 E.g. CRC/C/GC/12 (regarding children). See Guiding Principles on Business and Human Rights, principle 31(h) and commentary. See section II.B.4. 11