,. . .,. .,. . .,. ~~ ===·~- '=~~~~~======·-~-=~ The burden of proof is on the victim of human rights abuse to show and convince the court that the corporate veil must be pierced; Lack of proof of the link between the human right abuse and the complicity of the individual shareholder, director, trustee, or officer of the corporation, believed to be due to the highly secretive and confidential nature of corporate decision making; Be that as it may, literatures suggest that, from an international perspective, businesses could become involved or implicated in gross human rights abuses as shown by the following broad categories: • • • • cases where companies and their managers and staff have been accused of being directly responsible for acts amounting to gross human rights abuses; cases where governments and state authorities have engaged companies to provide goods, technology, services or other resources which are then used (it is claimed) in abusive or repressive ways; cases where companies have been accused of providing information, or logistical or financial assistance, to human rights abusers that has, it is claimed, "caused" or "facilitated" or exacerbated the abuse. This group of cases frequently (though not always) arises out of situations where state security services have been called in to assist with the resolution of some dispute or conflict surrounding the business activities; cases where companies have been accused of being "complicit" in human rights abuses by virtue of having made investments in projects or joint ventures or regimes with poor human rights records or with connections to known abusers. 78 Stated otherwise, business enterprises could either be primary perpetrators or secondary perpetrators. They are secondary perpetrators if they are complicit with other actors, such as the state. The concept of corporate complicity is recognized at the international level. In the succeeding discussions, information about cases involving agricultural workers and indigenous cultural communities are presented. 78 Zerk, J. (2013). Corporate liability for gross human rights abuses: Toward a fairer and more effective system of domestic law remedies. http://www.ohchr.org/documents/issueslbusiness/domesticlawremedies/studydomesticelawremedies.pdf (accessed October 30, 2016) 36