A/HRC/32/45 76. The Swedish National Action Plan on Business and Human Rights provides that the State will ensure that State-owned companies, where appropriate, conduct human rights due diligence in order to assess and address any significant risk to human rights. 77. In cases where due diligence is not mandatory for all State-owned enterprises and under all circumstances, the Working Group suggests that States define the criteria under which they will require State-owned enterprises to conduct human rights due diligence, such as the size of the enterprise, the type of enterprise and its operations, the political and human rights context and the industry sector in which it operates. G. Requirements of disclosure, transparency and reporting 78. Guiding principle 21 emphasizes the importance for businesses to communicate externally to account for how they address their human rights impacts. Similarly, the OECD Guidelines on Corporate Governance of State-Owned Enterprises recommend that “SOEs should report material financial and non-financial information on the enterprise in line with corporate disclosure standards, and including areas of significant concern for the state as an owner and the general public” (see sect. VI). 79. The corporate reporting trend is for increased requirements for report on nonfinancial information and performance, including human rights. The trend seems clearer with respect to large and State-owned companies.47 States can, and already do, require State-owned enterprises to report annually to their owners, including on how they have achieved the objectives related to sustainability and human rights. Data from the Global Reporting Initiative shows that, in 2013, 13 out of 45 countries48 had policies or initiatives for reporting on non-financial information, including on issues related to human rights, that specifically targeted State-owned enterprises.49 In China, half of the over 1,600 sustainability reports published in 2012 were issued by large State-owned enterprises and listed companies.50 80. Given those trends and the fact that transparency and accountability are prominent principles within most international guidelines, 51 the Working Group recommends that States take the additional step to systematically require the enterprises that they own or control to report on environmental, social and human rights performance. 81. States could also suggest or require that companies follow an established methodology to communicate on human rights issues, such as the Global Reporting Initiative G4 Sustainability Reporting Guidelines, which include references to the Guiding 47 48 49 50 51 18 with OECD guidance. Available at www.mneguidelines.oecd.org/chinese-due-diligence-guidelinesfor-responsible-mineral-supply-chains.htm. Global Reporting Initiative, Carrots and Sticks: Sustainability reporting policies worldwide –today’s best practice, tomorrow’s trends (2013); see also EU Directive 2014/95/EU regarding disclosure of non-financial and diversity information by certain large “public-interest entities” with over 500 employees. These were: Brazil, China, Ecuador, Finland, France, Iceland, India, Indonesia, Netherlands, Russian Federation, South Africa, Spain and Sweden. Global Reporting Initiative, Carrots and Sticks, p. 17. Ibid., p. 27. KPMG, Currents of change: The KPMG Survey of Corporate Responsibility Reporting 2015.