the ICC Working Group on Business and Human Rights today would commend to the UN Working Group, governments and other stakeholders, the following five principles regarding NAPs and urge their integration to your own recommendations and work in this area. 1...NAPs should be developed by all states, as a vital tool to promote effective implementation of the UNGPs – and to increase the accountability of governments to rights-holders, both inside and outside their territory...2...NAPs should in principle address the full scope of the UN Guiding Principles, across all three pillars...3...[A] robust baseline assessment or gap analysis needs to be undertaken as the first step of any NAP development process...NAPs process should be Participatory, Accountable, Non-discriminatory, Empowering and Legal, with reference to rights-holders...it is essential that their voices are heard, and their experiences captured and responded to, in a NAPs process...NAPs should include achievable and time-bound targets, milestones for delivery, and performance indicators, to permit periodic review on their achievement...and updating and revision, in line with performance and evolving challenges to human rights and responses.