The statement appears to repeat their positions without addressing our critique, for example to "not only require but also incentivize and support businesses to respect human rights." There they claim we misrepresent their point on incentives by saying it should be part of a smart mix and not replace legislation. However we are not saying they don't argue for legislation. We are questioning the absurd assumption that respecting human rights requires incentives and should be rewarded.

On the UNGPs - they are right that the sentence on legal liability is from the UNGPs, however when you place it in wider context of how they use the line (connected to limiting their liability for human rights abuses) - this was not the intention of the UNGPs which clearly says judicial remedy is key and calls for removing barriers to justice.

Finally, our central criticism is that they don't really want liability, or, if it will be forced on them, they make a number of proposals that would drastically weaken it (limiting it to only for severe violations (implying there are "un-severe" human rights violations), and to only tier 1, and including a due diligence defense). They don't react to this point at all, which seems to confirm our analysis that they propose no liability or a very weak form.