[comments contributed to Intl. Network for Economic, Social & Cultural Rights (ESCR-Net), in advance of ESCR-Net’s submission to UN stakeholder consultation on business & human rights]....the [UN] Norms have many advantages over existing international initiatives. For example, they support the notion of the indivisibility of all human rights, define the obligations with much more clarity and may be interpreted to have application to a wider range of non-state actors.