Resorting to Mechanisms
of International Institutions
This module has the following objectives:•

Enable the participants to discuss the advantages and disadvantages of using themechanisms that have been established by international institutions (such as theIntegrity Measures of the UN Global Compact and the National Contact Point [NCP]
system of OECD) to address human rights and labor issues.

Time: 4 hours and 15 minutes
Materials:• Big size papers, colored pens, writing papers, adhesive tapes;• Equipment - computer, projector, screen;• Video/documents on the international mechanisms such as the National Contact
Point of the OECD and the UN mechanisms.

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Resorting to Mechanisms of International Institutions
I. Procedurea. Opener - 30 minutes
Show a video on the National Contact Point (NCP) of the OECD. Ask the participants
for comments.
b. Input
Provide an input on international mechanisms to resolve cases of adverse human rights
impact:1. Integrity Measures of the UN Global Compact (Annex A)
2. National Contact Point of the OECD (Annex B).
Activity – 1 hour
In small groups, ask the participants to review in small groups the cases decided by the
NCPs and the Office of the UN Global Compact relating to Northeast Asian companies
such as the following:
1. Korean Trans National Corporations Watch, et al., v Daewoo International, POSCO,et al., ruling of the Korean National Contact Point, 3 December 2014 (Annex C);
2. Canada Tibet Committee vs. China Gold Int. Resources, Canada National Contact
Point, 29 January 2014 (Annex D); and3. Complaint against Petro-China filed in the Office of the UN Global Compact (Annex
E)
One group discusses one case. Use the text of the cases in the annexes.
Instruct them to take note of the process involved from the filing of complaint to theresolution of the case by the NCP or whatever stage the case has reached; who filed thecomplaint; reasons/explanations given the NCP, UN Global Compact on the cases.
Ask them to present the results of their discussion in the plenary.
List on the board the ideas/suggestions provided by the participants.
c. Input - 1 hour
Provide an input that answers the following questions:• How have the National Contact Points (NCPs) and the Integrity Measures addressed
the complaints brought before them?
• What are the limitations of the NCPs and Integrity Measures?
• What can be done to further improve the work of the NCPs and Global Compact
Office (regarding Integrity Measures)?
• What lessons can be learned from the use of the NCPs and Integrity Measures?
(See F Annex E for an assessment of a NCP)
d. Activity - 1 hour and 30 minutes
In small groups, ask the participants to• discuss the feasibility of using the NCPs by local stakeholders (workers, membersof the local community, etc.);

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•cite practical ideas/suggestions on the use of these mechanisms to resolve disputes
involving companies.
Instruct them to present the results of their discussion in the plenary.
II. Summary
Time: 15 minutes
Summarize the main points discussed during the session such as the following:
1. The existing international mechanisms to address “business-related human rights
impacts” of company operations especially the NCPs and the Integrity Measures;
2. The advantages and disadvantages of using these international mechanisms especially for local stakeholders.

A Facilitator’s Training Manual131Annex A
Integrity Measures
Allegations of Systematic or Egregious Abuses
The Global Compact welcomes any participant that pledges to work towards
implementation of the Global Compact principles through learning, dialogue, projects,
process improvements or other such measures. Moreover, it is not now and does
not aspire to become a compliance based initiative. Nevertheless, safeguarding the
reputation, integrity and good efforts of the Global Compact and its participants requires transparent means to handle credible allegations of systematic or egregious
abuse of the Global Compact’s overall aims and principles. The Global Compact Office
can assist or provide guidance in this regard, by means of the measures described
below. The purpose of these measures in the first instance always will be to promote
continuous quality improvement and assist participants in aligning their actions withthe commitments they have undertaken with regard to the Global Compact principles.
It should be noted that the Global Compact Office will not involve itself in any way in
any claims of a legal nature that a party may have against a participating company orvice versa. Similarly, the measures set out below are not intended to affect, pre-empt
or substitute for other regulatory or legal procedures or proceedings in any jurisdiction.
Thus, when a matter is presented in writing to the Global Compact Office, theOffice will:
1. use its judgement to filter out prima facie frivolous allegations. If a matter isfound to be prima facie frivolous, the party raising the matter will be so informed
and no further action will be taken on the matter by the Global Compact Office.
2. If an allegation of systematic or egregious abuse is found not to be prima facie
frivolous, the Global Compact Office will forward the matter to the participatingcompany concerned, requesting• written comments, which should be submitted directly to the party raising the matter, with a copy to the Global Compact Office, and• that the Global Compact Office be kept informed of any actions takenby the participating company to address the situation which is the
subject matter of the allegation. The Global Compact Office will informthe party raising the matter of the above-described actions taken by
the Global Compact Office.
3. The Global Compact Office would be available to provide guidance and assistance, as necessary and appropriate, to the participating company concerned,
in taking actions to remedy the situation that is the subject matter of the allegation in order to align the actions of the company with its commitments to
the Global Compact principles.
The Global Compact Office may, in its sole discretion, take one or more of thefollowing steps, as appropriate:
1. Use its own good offices to encourage resolution of the matter;
2. Ask the relevant country/regional Global Compact network, or other Global
Compact participant organization, to assist with the resolution of the matter;
3. Refer the matter to one or more of the UN entities that are the guardians of
the Global Compact principles for advice, assistance or action;

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4. Share with the parties information about the specific instance procedures of
the OECD Guidelines for Multinational Enterprises and, in the case of mattersrelating to the labour principles, the interpretation procedure under the ILO
Tripartite Declaration of Principles concerning Multinational Enterprises andSocial Policy.
5. Refer the matter to the Global Compact Board, drawing in particular on theexpertise and recommendations of its business members.
If the participating company concerned refuses to engage in dialogue on the matter within two months of first being contacted by the Global Compact Office undersubparagraph (b) above, it may be regarded as “non-communicating”, and would
be identified as such on the Global Compact website until such time as a dialoguecommences. If, as a result of the process outlined above and based on the review of
the nature of the matter submitted and the responses by the participating company,
the continued listing of the participating company on the Global Compact website isconsidered to be detrimental to the reputation and integrity of the Global Compact,
the Global Compact Office reserves the right to remove that company from the list ofparticipants and to so indicate on the Global Compact website.
A participating company that is designated “non-communicating” or is removed
from the list of participants will not be allowed to use the Global Compact name orlogo if such permission had been granted.
If the participating company concerned has subsequently taken appropriate actions to remedy the situation that is the subject matter of the allegation, and hasaligned its actions with the commitments it has undertaken with regard to the Global
Compact principles, the company may seek reinstatement as an “active” participant
to the Global Compact and to the list of participants on the Global Compact website.
If there is a local network in the country where the company is based, the company
should first approach the local network; in all other cases the Global Compact Officeshould be contacted directly. Only the Global Compact Office can make a final determination of reinstatement.
The Global Compact Office is committed to ensuring a fair process for the parties
involved. In order to promote the productive resolution of matters raised, no entity
involved in the process should make any public statements regarding the matter until
it is resolved.
(Source: Text based on Global Compact – Integrity Measures. Available at www.unglobalcompact.org/docs/about_the_gc/
Integrity_measures/Integrity_Measures_Note_EN.PDF)

A Facilitator’s Training Manual133Annex B
National Contact Point
The National Contact Point [NCP] will contribute to the resolution of issues thatarise relating to implementation of the Guidelines [OECD Guidelines for Multinational
Enterprises] in specific instances in a manner that is impartial, predictable, equitable
and compatible with the principles and standards of the Guidelines. The NCP will offer a forum for discussion and assist the business community, worker organisations,other non-governmental organisations, and other interested parties concerned todeal with the issues raised in an efficient and timely manner and in accordance withapplicable law. In providing this assistance, the NCP will:
1. Make an initial assessment of whether the issues raised merit further examination and respond to the parties involved.
2. Where the issues raised merit further examination, offer good offices to help theparties involved to resolve the issues. For this purpose, the NCP will consult
with these parties and where relevant:a. seek advice from relevant authorities, and/or representatives of the business community, worker organisations, other nongovernmental organisations, and relevant experts;
b. consult the NCP in the other country or countries concerned;c. seek the guidance of the Committee if it has doubt about the interpretationof the Guidelines in particular circumstances;
d. offer, and with the agreement of the parties involved, facilitate access toconsensual and non-adversarial means, such as conciliation or mediation,
to assist the parties in dealing with the issues.
3. At the conclusion of the procedures and after consultation with the parties
involved, make the results of the procedures publicly available, taking into account the need to protect sensitive business and other stakeholder information, by issuing:a. a statement when the NCP decides that the issues raised do not meritfurther consideration. The statement should at a minimum describe theissues raised and the reasons for the NCP’s decision;b. a report when the parties have reached agreement on the issues raised.
The report should at a minimum describe the issues raised, the procedures
the NCP initiated in assisting the parties and when agreement was reached.
Information on the content of the agreement will only be included insofar
as the parties involved agree thereto;c. a statement when no agreement is reached or when a party is unwilling toparticipate in the procedures. This statement should at a minimum describe
the issues raised, the reasons why the NCP decided that the issues raised
merit further examination and the procedures the NCP initiated in assisting
the parties. The NCP will make recommendations on the implementationof the Guidelines as appropriate, which should be included in the statement. Where appropriate, the statement could also include the reasonsthat agreement could not be reached.

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The NCP will notify the results of its specific instance procedures to the Committee
in a timely manner.
4. In order to facilitate resolution of the issues raised, take appropriate steps toprotect sensitive business and other information and the interests of otherstakeholders involved in the specific instance. While the procedures underparagraph 2 are underway, confidentiality of the proceedings will be maintained. At the conclusion of the procedures, if the parties involved have notagreed on a resolution of the issues raised, they are free to communicate about
and discuss these issues. However, information and views provided during
the proceedings by another party involved will remain confidential, unless that
other party agrees to their disclosure or this would be contrary to the provisions of national law.
5. If issues arise in non-adhering countries, take steps to develop an understanding of the issues involved, and follow these procedures where relevant andpracticable.
(Source: OECD Guidelines for Multinational Enterprises, 2011 edition, OECD Publishing, pages 72-74. Available at http://dx.doi.
org/10.1787/9789264115415-en)

A Facilitator’s Training Manual135Annex C
National Contact Point - Cases
KTNCW et al. vs. Daewoo, et al.
Case overview
Date filed: 3 December 2014
Current status: Rejected (7 July 2015)
Issue: Daewoo’s use of cotton harvested with forced & child labour
Summary of the caseUzbekistan is one of the few countries around the world that through the implementation of state policy subjects its citizens to forced labour. The government forcibly
mobilises farmers to grow cotton and forces more than a million men, women andchildren to harvest it. Since its first investment in Uzbekistan in the 1990s, Daewoo
has expanded to three factories and is currently the country’s largest cotton processor, buying 5% of all Uzbekistan’s cotton. In return, the Uzbek government provides
Daewoo with discounted cotton prices, tax incentives and preferential loans.
The complainants have been in direct contact with Daewoo since 2012. The company repeatedly admitted to having purchased cotton produced with forced and childlabour. Nevertheless, the complaint alleges that Daewoo refuses to cease purchasing
forced-labour cotton or to conduct independent human rights monitoring of its supply chain in Uzbekistan. It also alleges that Daewoo failed to conduct comprehensive
human rights due diligence in its supply chain and contributes to the ongoing humanrights violations associated with the cotton harvest in Uzbekistan.
The complainants also ask Daewoo’s parent company POSCO to take its responsibility to avoid contributing to human rights violations in its subsidiary’s operations
and supply chains. Complaints have also been filed against Norwegian pension funds
NPS and NBIM, requesting that as institutional investors of Daewoo International, they
use their leverage to ensure that they mitigate the adverse human rights impacts towhich they are directly linked to through their financial relationship with Daewoo.
Developments/Outcome
After an extension to carry out its initial assessment, the Korean NCP rejected thecomplaints against Daewoo, POSCO and NPS in July 2015. The NCP recognised
the internal guidelines for ethical business conduct that the companies have in placeand could not establish that they have breached the due diligence provisions of theOECD Guidelines or contributed to child labour and forced labour. The NCP further
takes into consideration that the companies are not in a position to have leverageover the Uzbek government.
Given its relatively recent conclusion of a complaint against NBIM on the same
issues and the ongoing clarification process at OECD level on the application of theOECD Guidelines to the financial sector, the Norwegian NCP decided to close thecase without further consideration in July 2015. The NCP did not reject the complaint,
but concluded that a new examination of same questions of principles concerning thefinancial sector’s compliance with the Guidelines will not contribute to the purposeof the OECD Guidelines. In its statement the NCP did make reference to its previous

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decision and recommendations to NBIM formulated at the conclusion of a complaint
filed by ForUM and concluded by the NCP in May 2013.
(note: list of relevant OECD Guidelines not included in this Annex)
Case keywords
Child labour, Forced labour
NCP Information
NCP name: National Contact Point Korea
NCP address: 1 Chungang-dong Gwacheon-si, Kyonggi-do, Korea, Republic of
NCP website: www.mocie.go.kr/
Other NCPs involved: National Contact Point Norway
ComplainantsNGO
Anti-slavery International
Cotton Campaign
Korean Trans National Corporations Watch
Source: www.oecdwatch.org/cases/Case_354

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National Contact Point - Cases
Canada Tibet Committee vs. China Gold Int. Resources
Case overview
Date filed: 29 January 2014
Current status: Concluded (1 April 2015)
Issue: Environmental, HR & disclosure issues China Gold Int.
Summary of the caseOn 29 March 2013, Chinese state media reported that 83 miners were buried
after a major landslide hit part of the Gyama Copper Polymetallic Mine located in the
Pulang Valley in Siphug Village of Tashi Gang Town in Central Tibet (Tibet Autonomous
Region). There were no survivors. The workers were reportedly asleep in their tents
when they were buried by a mass of mud, rocks, and debris that was three kilometreswide and thirty metres deep. The camp where the workers were buried belongs to
Tibet Huatailong Mining Development Ltd., a wholly-owned subsidiary of China Gold
International Resources.
Although the Chinese government has stated that the landslide was a natural disaster, CTC alleges that there is documented evidence that it was in fact a manmade
disaster and that the company had ignored previous warnings and local protests.
In addition, the complaint describes numerous other disputes with local stakeholders that remain unresolved and are indicative of a range of continuing violationsof the Guidelines.
The complaint was filed by CTC because members of affected communities areunable to bring forward public complaints for reasons of personal security.
Developments/Outcome
After confirming receipt on 28 January, CTC did not hear from the NCP until 17
April, when the NCP informed CTC that China Gold was unwilling to engage in theprocess despite multiple requests from the NCP.
Though it never formally issued an initial assessment, in April 2015 the Canadian
NCP released a final statement “accepting” the case and concluding that China Gold
had not demonstrated that it is operating in a manner that can be considered to beconsistent with the OECD Guidelines.
Interestingly, in its final statement, the NCP took the unprecedented step of imposing sanctions on the company for failing to engage in the complaint process,including withdrawing Trade Commissioner Services and other Canadian advocacy
support abroad. This is a first in the NCP system. The sanctions can be repealed if
the company eventually does engage with the NCP or somehow shows that it has
engaged in good-faith dialogue with CTC.
The final statement also made recommendations to China Gold with respect tohuman rights due diligence including the importance of undertaking human rights
impact assessments of the potential impacts of anticipated activities, and of disclosing any past or future reports.
(note: list of relevant OECD Guidelines not included in this Annex)

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Case keywords
Health and safety, Extractives / mining sector, Forced evictions and resettlement,
Labour rights, Human rights, Environment, Disclosure of information
NCP Information
NCP name: National Contact Point Canada
NCP website: www.ncp-pcn.gc.ca/
ComplainantNGO
Canada Tibet Committee
Source: www.oecdwatch.org/cases/Case_324

A Facilitator’s Training Manual139Annex E
Complaint Against Petro-China
In a 12 May 2008 letter, an international group of NGOs requested the UN Global
Compact Board to exercise its authority under the so-called “Integrity Measures” tohold PetroChina accountable for the Darfur crisis. The group asked the Board torequest PetroChina to 1) engage the Sudanese government, either independently orcollectively with other foreign oil companies operating in Sudan, to implement the UN
Security Council resolution on ending the conflict in Darfur; 2) make all possible efforts
to contribute to the success of Sudan’s Comprehensive Peace Agreement (CPA),
including utilizing leverage on its business affiliates on the [government of Sudan] andon the government of South Sudan, to ensure that the CPA is implemented without
further delay. This group of NGOs subsequently filed a formal complaint on the issue
with the UN Global Compact Board on 15 December 2008. The formal complaint
has two major issues: a. Are signatory-companies accountable under the UN Global
Compact for the actions of their shareholders? And if the shareholders were companies, can UN Global Compact hold them accountable regardless of their non-signatory
status? b. Are signatory-companies accountable under the UN Global Compact for
any link to activities of other companies that allegedly support the human rights violations of host government?
The response of the UN Global Compact Office (through the letter of the Vice-Chairof the Global Compact Board on 9 February 2009) addresses the two issues. On thefirst issue, the letter explains that PetroChina (a signatory to the Global Compact) is
not operating in Sudan and thus cannot be held responsible for the crisis there. And
while the China National Petroleum Company (CNPC), the “dominant majority shareholder” of PetroChina, operates in Sudan it is not a signatory to the Global Compact
and thus it is not covered by the integrity measures. The letter cites the difficulty ofholding a subsidiary “responsible for the activities of a non-signatory shareholder, even
if that shareholder holds a significant majority of the shares.” A prior response by the
Executive Director of the UN Global Compact Office to the NGO request to delist
PetroChina says that the Global Compact Board decided “not to handle this matteras an integrity issue of an individual company, PetroChina” and that the UN “Global
Compact’s approach to business and peace emphasizes engagement rather than divestment and the power of collective action rather than focusing on any one individualcompany.” On the second issue, the complaint argues that any company that takes“part in any activity which is a source of major government revenue is by definition
complicit with any human rights [violations] of the host government whether or notthere is direct connection with the company’s activities.” In this case, the “company
should then either engage with the government in order to persuade it to desist [fromcommitting human rights violations], or presumably withdraw from the country.” Theletter of the Vice-Chair of the UN Global Compact, however, states that “companies
have to make their own decisions based on whether they feel able to operate in linewith the principle they subscribe to as well as any advice or sanction from their homegovernment and of course whether there are United Nations sanctions involved.”(Source: Huang Zhong and Chen Qian, “Merging Business and Human Rights in China: Still a Long To Go,” in Bridging Human Rights
Principles and Business Realities in Northeast Asia, pages 40-42. Endnotes have been omitted.)

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Annex F
Assessment of the Australian NCP by Monash University, the University of Melbourne
and Deakin University’s Non-Judicial Human Rights Mechanisms Research Project,
April 21st, 2014
Has the NCP changed its structure or procedures in the present implementation cycle?
Although the Australian National Contact Point (ANCP) has not changed its structure or procedures in the past period, the establishment of the oversight committee in2012 as a direct response to the 2011 review of the Guidelines is important to note.
The prime duty of the committee is to assist the ANCP when complaints are madeand there are contentious issues to be considered. Although it was introduced aspart of the structure of the ANCP and members are expected to meet biannually, the
ANCP website only has records of the minutes from its First Meeting in November
2012 suggesting that it has not been active. We encourage the ANCP to ensure an
active role for the oversight committee.
How do you assess the general functioning and structure of the NCP in yourcountry you have been in contact with?
The ANCP is considered to be relatively weak, even after the oversight body wasestablished. The ANCP is under-resourced and its determination processes are lessrigorous than ‘best practice’ NCPs. The ANCP receives significantly less funding
than the model NCPs (UK, Dutch, Norway). It does not have a dedicated budget
or any designated staff, and instead is supported by staff of the Foreign Investment
and Trade Policy Division of the Commonwealth Treasury.* As a result of its lack offunding, its ability to investigate specific instance complaints, conduct consultations
within Australia, participate at OECD meetings, and promote the OECD Guidelines isdetrimentally affected. Whilst the ANCP is one of the 15 (33%) NCPs that have created a multi-stakeholder board** the continuing functionality of this board is in question (as discussed above). The ACNP is not very active when compared with other
NCPs, and there is no reason to believe that Australian companies have better humanrights records than companies based elsewhere in the OECD. It has only received 12
cases, of which 5 have been concluded, 5 rejected, 1 withdrawn and 1 still pending.***If the ANCP chooses to refuse mediation or mediation fails, it does not continue toinvestigate the complaint and it does not make an assessment of whether a company
has breached the Guidelines. This is an area where Australia is failing to uphold the
Guidelines. Furthermore, where mediation is successful and the NCP releases a final
statement, it does not have a follow up process to monitor a company’s compliancewith its recommendations.**** This allows multinational enterprises that are in violationof the Guidelines to avoid implementing the recommendations of the NCP to bringthemselves in line with the Guidelines. The ANCP performs well by having a dedicated website with adequate web pages explaining its function and role. Key OECD
materials on the Guidelines are accessible on the website in English. Far more canbe done to improve accessibility, however, such as more thorough outreach activities* Trade Union Cases, National Contact Point Comparison.
** Trade Union Cases, National Contact Point Comparison.
*** OECD Watch, NCP: National Contact Point Australia.
**** Trade Union Cases, Australia NCP.

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and the publication of materials in different languages. The ANCP offers reasonablelevels of transparency by publishing its initial statement in the complaint process andprovides mediation to parties for the purpose of resolving disputes. The NCP uses
independent mediators in this process, and upon the conclusion of the mediation
process it publishes a final statement to the public which includes recommendations
to the company on future implementation of the Guidelines. Despite this, there ismuch room for improvement within the ANCP.*****How do you assess the performance of information and promotion functionof the NCP in your country?
The ANCP complaint process is well publicised on their website. The website details information on the stages involved in handling complaints, the review procedure
for complaints, and provides time limits for each stage. However, in Australia, the NCP
is not a widely known mechanism and the NCP itself does little promotional work. The
ANCP website states that their role includes the promotion of the Guidelines and thatthey do this by undertaking activities such as conducting seminars and consultation
session on the Guidelines with businesses, NGOs, government departments andagencies, and the interested public; and publicising a Service Charter on the role of
the ANCP to multinational enterprises and more broadly.****** However, in practice, there
is no evidence of these outreach activities being conducted in any substantive form.
As a result, concerns have been raised about the lack of accessibility to the ANCP
due to the lack of promotional activities undertaken. Furthermore, the NCP website
states “Consultations are held at least once a year to complement the schedule ofmeetings of the OECD Committee on Investment. These sessions aim to provide aforum for stakeholders to address issues under the Guidelines with the ANCP and topromote the Guidelines as a useful framework for business.”******* However, membersof OECD Watch complain that although there used to be 3 meetings a year in Sydney,
Melbourne and Canberra, which operate as multi- stakeholder consultations, theseno longer occur. According to the Trade Union Cases (TUAC), the ANCP does nothold regular consultations in cooperation with external stakeholders, including tradeunions, and it does not organise events to promote the Guidelines either in Australia
or abroad.********
Whilst the ANCP does have publications and key materials on the OECD Guidelines
and reports from the Annual Meeting of NCPs, it has not been updated since 2012,
which further limits its information and promotion function.
Other comments
With respect to the structure of the ANCP, it is housed in a single government
department, the Foreign Investment and Trade Policy Division at the Commonwealth
Treasury. In general, scepticism has been expressed regarding the independenceof the ANCP (from ACTU and Oxfam Australia) and its ability to operate impartiallythroughout the complaints process as the structure can influence how the NCP
handles complaints. For example, decision-making by the ANCP ultimately sits within
this government department which can result in conflicts of interest. Thus, the ANCP***** Trade Union Cases, Australia NCP.
****** Australian Government, Implementation and Promotion.
******* Australian Government, The Australian National Contact Point.
******** Trade Union Cases, Australia NCP.

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should consider having an independent location to avoid conflicts of interest withthe goals of the Guidelines. In short, the Australian NCP is falling short of achieving
the four core criteria of functional equivalence of NCPs recommended in the 2011
Guidelines. Though it is formally visible, accessible, transparent and accountable, inpractice it takes a very minimalist approach to meeting these criteria and that has
impacted adversely on its usefulness as a grievance mechanism and promoter ofhuman rights in the Australian business community.
(Source: OECD Watch, Assessment of NCP Performance in the 2013-2014 Implementation Cycle, June 2014, pages 36-38. Availableat www.oecdwatch.org.)

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References
Norwegian National Contact Point, Final Statement - Complaint from Lok Shakti Abhiyan,
Korean Transnational Corporations Watch, Fair Green And Global Alliance and Forum For
Environment and Development Vs. POSCO
Assessment of the Australian NCP by Monash University, the University of Melbourne
and Deakin University’s Non-Judicial Human Rights Mechanisms Research Project, 21
April 2014
Caitlin Daniel, Joseph Wilde-Ramsing, Kris Genovese, Virginia Sandjojo, Remedy
Remains Rare (Amsterdam: OECD Watch, 2015)
National Contact Point, HURIGHTS OSAKA, “Human Rights and Japanese Companies,”
pages 165 - 172; and Appendix C, pages 203-204, in Jefferson R. Plantilla, editor, Bridging
Human Rights Principles and Business Realities in Northeast Asia (Osaka/Kuala Lumpur:
HURIGHTS OSAKA and SIRD, 2014)

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