In seeking to realize the application of the Constitution to companies, it is important that concrete steps be taken to ensure that the company form is not used to shield corporations from their responsibilities to realize human rights...[T]he structures established by the Companies Act must conform with constitutional constraints. This means that the notion of creating a structure which can pursue profits at the expense of human rights is no longer legally meaningful...We recommend four main reforms to the Companies Bill...In particular, the Companies Bill should...first specify that corporations are required to place in their memorandum of association that they recognise that they are bound by the rights in the Bill of Rights and are responsible for their realisation to the extent that they bear responsibility for them. This would make the protection and realisation of fundamental rights one of the prime constraints on the activities of the company.