A/63/263 7. In conjunction with other pharmaceutical companies, the company should agree to standard formats for the systematic disclosure of company information and data bearing upon access to medicines, thereby making it easier to evaluate the performance of one company against another, as well as the performance of the same company over time. 8. Either alone or in conjunction with others, the company should establish an independent body to consider disputes that may arise regarding the disclosure or otherwise of information relating to access to medicines. That body may be the monitoring and accountability mechanism referred to in Guideline 14. Commentary: Transparency is another cardinal principle of international human rights, including the right to the highest attainable standard of health. It is not possible to properly understand and meaningfully evaluate access to medicines policies and practices without the disclosure of key information. There is a presumption in favour of disclosure, which may be rebutted on limited grounds (Guideline 6). Commonsense confirms that the principle of transparency not only requires that information be made publicly available, it also requires that the information be made publicly available in a form that is accessible, manageable and useful (Guideline 7). An independent, trusted and informal body should be established to consider any disputes that may arise about whether or not a particular piece of information relating to access to medicines should be disclosed (Guideline 8). That body should also provide guidance on the legitimate grounds of non-disclosure. While Guidelines 6-8 have general application to access to medicines, other Guidelines apply the cardinal principle of transparency in specific contexts, such as public policy influence, advocacy and lobbying (Guidelines17-19). Management, monitoring and accountability 9. The company should encourage and facilitate multi-stakeholder engagement in the formulation of its policies, programmes, projects and other activities that bear upon access to medicines. In keeping with Guideline 5, this engagement should include the active and informed participation of disadvantaged individuals, communities and populations. 10. The company should have a publicly available policy on access to medicines setting out general and specific objectives, time frames, reporting procedures and lines of accountability. 11. The company should have a governance system that includes direct boardlevel responsibility and accountability for its access to medicines policy. 12. The company should have clear management systems, including quantitative targets, to implement and monitor its access-to-medicines policy. 13. The company should publish a comprehensive annual report, including qualitative and quantitative information, enabling an assessment of the company’s policies, programmes, projects and other activities that bear upon access to medicines. 14. In the context of access to medicines, internal monitoring and accountability mechanisms have a vital role to play, but they should also be supplemented by a mechanism that is independent of the company. Until such a 18 08-45647