...The Thun Group paper seeks to develop a conceptual framework for considering Principle 13 of the UN Guiding Principles on Business and Human Rights (UNGPs) for banks in a corporate and investment banking context. However, it begins with the flawed assertion that only half of Principle 13 applies in the case of human rights impacts linked to bank finance...Building on this flawed starting point, the paper misrepresents the rights of people who may be affected by business activities to access to remedy, and goes on to omit the responsibility of banks to respect the (human) right to remedy - part of the responsibility to respect all human rights - and provide complaints channels for affected people....