Recommendations for National Action Plans on Business and Human Rights B. Domestic / overseas standards and cases 1) UNGPs 4. States should take additional steps to protect against human rights abuses by business enterprises that are owned or controlled by the State, or that receive substantial support and services from State agencies such as export credit agencies and official investment insurance or guarantee agencies, including, where appropriate, by requiring human rights due diligence. 2) The UN Guiding Principles above indicate that the government is the primary duty-bearer to protect human rights. Therefore, the government is obliged to prevent human rights abuses by State-owned or State-controlled enterprises, or to mitigate the negative impact on human rights by business enterprises that receive substantial support from State agencies. 3) European countries have already recognized the corporate social responsibility including human rights, introduced and implemented policies on public corporations and institutions to internalize their responsibility. In addition, these countries have taken social factors including human rights into account when supporting business enterprises through public financial organizations such as export credit agencies, and required business enterprises taking part in development aid projects to pay attention to human rights. For example, California Public Employees’ Retirement System, the Public Pension of the Netherlands and the Norwegian Pension Fund reflected social factors including human rights in investment decisions, thereby directly and indirectly requiring business enterprises to consider human rights. 14