A/63/263 mechanism is established by others, the company should establish an effective, transparent, accessible and independent monitoring and accountability mechanism that: (a) Assesses the impact of the company’s strategies, policies, programmes, projects and activities on access to medicines, especially for disadvantaged individuals, communities and populations; (b) Monitors and holds the company to account in relation to the present Guidelines. Commentary: All human rights, including the right to the highest attainable standard of health, require effective, transparent and accessible monitoring and accountability mechanisms. The mechanisms have a variety of forms; usually a mix of mechanisms is required. While some mechanisms are internal, others are external and independent; both types are needed. Guidelines 9-13 address the issue of internal corporate monitoring and accountability regarding access to medicines. Guideline 14 addresses the issue of an external, independent monitoring and accountability mechanism regarding access to medicines. Corruption 15. A company should publicly adopt effective anti-corruption policies and measures, and comply with relevant national law implementing the United Nations Convention against Corruption. 16. In collaboration with States, the company should take all reasonable measures to address counterfeiting. Commentary: Corruption is a major obstacle to the enjoyment of the right to the highest attainable standard of health, including access to medicines. Those living in poverty, for example, are disproportionately harmed by corruption because they are less able to pay for private alternatives where corruption has depleted public health services. Numerous features of the right to the highest attainable standard of health, such as transparency, monitoring and accountability, help to establish an environment in which corruption can neither thrive nor survive. In short, a right-tohealth policy is also an anti-corruption policy. As emphasized in the Preamble, improving access to medicines is a responsibility shared by numerous national and international actors; Guideline 16 provides one specific example of this shared responsibility in relation to counterfeiting. 12 Public policy influence, advocacy and lobbying 17. The company should disclose all current advocacy and lobbying positions, and related activities, at the regional, national and international levels that impact or may impact upon access to medicines. 18. The company should annually disclose its financial and other support to key opinion leaders, patient associations, political parties and candidates, trade associations, academic departments, research centres and others, through which it seeks to influence public policy and national, regional and __________________ 12 08-45647 Counterfeit drugs (medicines) are defined by WHO in FAQ’s on Counterfeit Drugs, 2008. 19