STRATEGIC FRAMEWORK ON A NATIONAL ACTION PLAN ON BUSINESS AND HUMAN RIGHTS FOR MALAYSIA (17) Provide effective State-based non-judicial grievance mechanisms to complement and supplement judicial mechanisms in providing effective remedy for business-related human rights abuses 117. Non-judicial mechanisms, both State-based and non-State-based, are an important complement and supplement to judicial mechanisms. As noted by the commentary to the Guiding Principles, “judicial remedy is not always required; nor is it always the favoured approach by claimants.”110 Non-judicial mechanisms can be a much needed alternative where gaps in access to effective judicial remedy exist. They may also have benefits that judicial mechanisms may not have, such as early recourse and prevention, opportunity for creativity and flexibility in remediation options, lower costs and more speedy resolution. Moreover, they help alleviate the burden on the judicial machinery. 118. The Government should consider expanding the mandates of existing State-based non-judicial mechanisms to fill gaps in the provision of remedy for business-related human rights abuses. The commentary to the Guiding Principles notes that NHRIs have “a particularly important role to play in this regard.”111 As mentioned above, the Commission has received complaints regarding business-related human rights abuses. The Commission, as a statutory body established under an Act of Parliament, is an appropriate body to serve as a grievance mechanism for business and human rights issues. However, as the Commission has earlier proposed to the Government, its powers to address these complaints should be strengthened.112 119. Another potentially relevant mechanism is the Integrity Unit in individual Government ministries and agencies, and Certified Integrity Officers that some GLCs and other private companies have. This integrity initiative is administered by the MACC, and involves the establishment of independent Integrity Units in individual public agencies, and the voluntary appointment by private companies of Certified Integrity Officers. These integrity units and officers may be a better alternative to the ordinary administrative complaints processes of ministries and regulatory agencies, as they may have greater independence. The mandate, capacity and resources of these units and officers could be expanded to include addressing complaints regarding business-related human rights abuses that involve corruption. 120. The Government should also consider adding new State-based non-judicial grievance mechanisms to specifically address business and human rights issues. The Commission’s consultation participants have suggested establishing non-judicial grievance mechanisms, such as alternative dispute resolution processes, to address complaints of non-compliance with standards for responsible business conduct. An OECD NCP would be such a mechanism. 121. Non-judicial grievance mechanisms could be established at State-linked development and investment finance institutions. The large-scale impacts of development projects and the financial leverage that these institutions have in relation to the projects they support are some of the reasons why MDBs and the development and investment finance institutions of other countries have established their own accountability mechanisms. Non-judicial grievance mechanisms could 37