We commend the Working Group’s initiative to engage stakeholder input on the work plan…We believe that actively incorporating the investor perspective is an important element for the successful implementation of the “Protect, Respect and Remedy” framework…the Guiding Principles do not address directly the special position of influence held by investors…to either support or hinder the efforts of companies to implement robust human rights policies and due diligence processes. Nor do they emphasize that the responsibility of all businesses to respect human rights also applies to investment institutions. We believe these are significant gaps.. .we encourage the Working Group to explore how the corporate responsibility to respect human rights applies to investment institutions, and how it can be integrated within the scope of fiduciary duty. We further suggest that the Working Group could liaise with the UN Principles for Responsible Investment and the UNEP Finance Initiative to further this exploration