ICAR believes that the Guiding Principles do not provide a set of clear, well-defined, and measurable standards that would be capable of establishing an effective system for auditing and comparing businesses’ implementation of commitments to respect human rights. Further, using the Guiding Principles in this manner may also have the unintended effect of diluting efforts of existing multi-stakeholder initiatives that already require independent monitoring and have clearer and stronger standards. Additionally, ICAR is concerned that lessons learned from previous third-party auditing regimes indicate the weakness of these systems in compelling companies to take effective action to implement even clear commitments...ICAR is concerned that the Reporting Standard as envisioned by Mazars and Shift would lead to the development of the Guiding Principles as the limiting standard for corporate reporting on human rights...