It maps each step, process, and entity in a business’ value chain and identifies where people’s human rights can be affected. 60 In practice, companies conduct value chain mapping by first drawing a full map of the risks to people and communities across their operations and value chain. For instance, in Heineken’s mapping, it assessed human rights risks from brand promoters in outlets serving its beers, down to smallholder farmers who are often several steps removed from Heineken’s operations.61 4.3. Ensure effective and gender-transformative remediation mechanisms The UNGP-BHR describes both judicial and non-judicial remediation mechanisms. Thus, on top of the State-based judicial and non-judicial mechanisms, companies must develop OGMs. Role of the State to improve accountability As the primary duty-bearer in the protection, respect, and fulfillment of human rights, the State has an obligation to improve the accountability and access to remedies of victims of human rights abuse in a corporate setting through State-based mechanisms. This State obligation is highlighted in the Accountability and Remedy Project of the UN Office of the High Commissioner on Human Rights (OHCHR). Through a resolution, the UN OHCHR provided general observations and recommendations ons the role of State-based non-judicial mechanisms in enhancing accountability and access to remedy, which include a set of policy objectives supported by a series of elements to demonstrate the ways by which States can work toward meeting the objectives.62 Operational-level grievance mechanisms Many companies already have mechanisms for grievances and complaints both for their employees and consumers, including trade unions, whistle-blower policies, reporting mechanisms for sexual harassment, employee conflict management, safety incident reporting, and complaints procedure.63 The UNGP-BHR expects businesses to establish operational-level grievance mechanisms. Businesses must map and assess existing OGMs to determine where gaps may exist and address these to meet the six criteria identified by the UN Human Rights Council in 2008 (See Figure 7). It must also be proportionate to the scale of operation, culturally-appropriate, and safe for the reporting party. In case a company does not have an OGM, it must put in place such mechanisms consistent with the criteria. It includes establishing a committee on decorum and investigation responsible for receiving and investigating sexual harassment and gender-based violence in the workplace. Figure 7: Effectiveness Criteria for Non-Judicial Mechanisms Criteria 1 Legitimacy Criteria 2 Accessibility Criteria 3 Predictability Criteria 4 Equitability Criteria 5 Rights-compatibility Criteria 6 Transparency It is crucial to keep in mind that these three steps of applying and complying with the UNGPBHR are interrelated and complement each other (See Figure 8). Human rights governance is the overarching function as it lays down the policies a business will implement in respect of human rights and outlines the actions it will take in acting with due diligence and remedy victims in case of abuse. This linkage means that the absence of one element will render the other aspects ineffective. 17