A/HRC/35/37 schemes and their use of audits as a verification method have failed to protect the rights of workers. 42. Voices have been raised against the lack of worker and civil society representation in the governance structures of voluntary standards initiatives. The control that businesses may have over the participation of such actors has also been denounced as a strategy to exclude dissenting voices and bring down the level of the standards to that of the lowest common denominator practices among the businesses concerned. 43. During the consultation, private sector stakeholders expressed concern about the difficulty of designing a system that could efficiently support the efforts of companies moving at different speeds in achieving sustainability targets. It is difficult for multistakeholder organizations to address the capacity-building needs of those starting to implement measures to achieve baseline targets, while responding to others who are seeking a platform to launch new tools to move beyond baseline targets towards higher levels of corporate due diligence. 44. Auditing, as a way to evaluate the compliance of companies with labour standards, has also been criticized for its lack of capacity to assess the performance of companies in the long term. An audit, even the most comprehensive, i.e., when it includes worker interviews and is supplemented with information from alternative sources, such as local actors, including representatives of civil society and local trade unions, is still a snapshot offering only a partial view of day-to-day working conditions. 45. At the same time, representatives from the auditing community raised concerns about their limited role in addressing audit findings and the implementation of their recommendations. Moreover, many of the issues that constitute the root causes of common labour abuses identified at the supply chain level, such as those related to unethical recruitment practices and compulsory overtime, are strongly connected to the behaviour and business decisions of client companies. Some representatives of the auditing community also noted the difficulties faced in bringing such concerns to the attention of client companies, given the race-to-the-bottom practice encouraged by some in the audit industry who agree to perform audits under unrealistic conditions. 46. Furthermore, given the impact that the results of an audit evaluation may have on the business relationships with suppliers, the practices of presenting model factories prepared specifically for audits and model workers coached to respond to auditors have proliferated in the past few years. These practices aggravate yet another challenge of current auditbased monitoring systems, which is the concentration of company resources in monitoring the first tier of their supply chains. It is widely acknowledged that most of the human rights violations and the worst labour abuses occur beyond the first tier of suppliers. However, few companies have extended their due diligence efforts throughout the entire value chain or to include their labour supply chains. 47. This lack of accountability at lower levels of the supply chain inhibits the multiplier effect that efforts to implement the standards should have in bringing the larger group within the industry under the same standard. Companies’ leverage over their suppliers in today’s complex supply chains, in which individual companies may represent a small percentage of a supplier’s business share, can prove very limited if it is not accompanied by a collective action from the industry as a whole. While efforts by industry coalitions and multi-stakeholder initiatives are aimed at breaking through such barriers, current individual corporate limits on supply chain transparency hinder the use of powerful tools such as the consumer thirst for greater accountability, as lower levels in the supply chain hidden by a lack of transparency would be immune to such demands for accountability. Also, suppliers whose business relationships are predominantly with companies based in countries where there is a higher level of consumer awareness and where national legislation requires a higher degree of due diligence and transparency will respond differently to their buyers’ requirements regarding compliance with human rights and labour standards than will suppliers whose main business relationships are with companies based in countries with less robust national frameworks and lower consumer demand for ethically produced goods. 48. With regard to sector transformation, industry, multi-stakeholder and certification initiatives hold internal discussions on how to move beyond the engagement of a single 10