Western electronics at the heart of Russian warfare, the solar- automotive and garment industries’ ties to forced labour in the Xinjiang Uyghur Autonomous Region and the Palm Oil Industry’s links to devastating environmental and human rights consequences are just three examples of how internationally operating businesses are linked to the breaching of fundamental rights of peoples and communities around the world. While corporate activity has globalized, the regulation of the adverse consequences of corporate activity is lagging. The resulting governance gaps have provided ‘a permissive environment for wrongful acts by companies of all kinds without adequate sanctioning or reparation’. The 2011 Protect, Respect and Remedy Framework for Business and Human Rights, together with the UN Guiding Principles on Business and Human Rights (UNGPs) sought to start closing these governance gaps. The voluntary UNGPs urge states to observe their duty to protect and take ‘appropriate steps to prevent, investigate, punish and redress such abuse through effective policies, legislation, regulations and adjudication’ (UNGP 1), also for ‘their’ corporations operating abroad.