…The WG…has to work on a complex issue that brings together many different types of violations and victims, and…deals with the role of private actors in human rights abuses…Just like other special mechanisms, the WG should address individual complaints, undertake studies, assist in technical cooperation, and take part in general human rights promotion activities…[I]n its first two-and-a-half years, the WG has given priority to some of its functions to the detriment of others…The focus given to “best practices” and to the dissemination of the Guiding Principles…tends to ignore…the asymmetric power relations between victims and enterprises. By refraining from adopting an explicitly pro-victims approach, the WG contributes little to changing the regrettable situation we live in today…Our comments revolve around five critical topics [with recommendations]: 1. Absence of a clear and public Work Plan…2. Restrictive Interpretation of the Mandate granted by the Human Rights Council…3. Shortcomings in Addressing Alleged Violations…4. Regressive Application of the International Human Rights Law…5. Little Room for Victim Participation…