Efforts to further elaborate the core concepts of the UN Guiding Principles (GPs) and the ...OECD Guidelines (GLs) at more granular levels for particular business sectors and operational contexts are helpful...what is not helpful is the introduction of new language that is inconsistent with and potentially undermines their actual and intended meaning. Examples include the use in the Debevoise paper of such terms as business conduct that "materially increases" the risk of harm as a determinant of "cause," and company "benefits" in relation to its being "linked" to harm. The Thun Group of Banks uses the term "proximity" to harm by banks, and claims that it is determined by the nature of the financial product or service. These are unhelpful because they have no basis in and are not aligned with the GPs and GLs.