[T]he International Corporate Accountability Roundtable...believes that the Articles of Association of the ICoC...offer considerable improvements from the prior Draft. However, ICAR is concerned that the Articles...do not clearly provide the Mechanism with sufficient independence or authority to establish effective leadership and oversight of the industry efforts to identify, prevent, mitigate and account for the human rights impacts of their activities...ICAR believes that the...certification criteria...must permit the Mechanism to consider guidelines that, unlike national standards, are human rights-protective. The reference to “national and international standards”...excludes consideration of an emerging range of guidelines on the issues addressed by the ICoC and developed in collaboration between industry and civil society and with reference to the UN Guiding Principles, the Global Compact, and other human rights oriented frameworks.