strengthen the remedies for people who have been victims of activities of such business enterprises operating abroad, as well as strengthen the safeguards to prevent people from becoming victims to these.”8 The International Covenant on Economic, Social and Cultural Rights (ICESCR), using somewhat different formulations, imposes similar obligations on States. The ICESCR, to which the Philippines is a party, requires that “[e]ach State Party to the present Covenant undertakes to take steps, individually and through international assistance and co-operation, especially economic and technical, to the maximum of its available resources, with a view to achieving progressively the full realization of the rights recognized in the present Covenant by all appropriate means, including particularly the adoption of legislative measures.” 9 The Committee on Economic, Social and Cultural Rights (CESCR), the supervisory body for the ICESCR, has further articulated and expanded on this duty to protect in its jurisprudence and general commentary, including its general comments on the right to food, and the right to water. 10 With regards to the right to food and the duty to protect, the CESCR stated, “[t]he right to adequate food, like any other human right, imposes three types or levels of obligations on States parties: the obligations to respect, to protect and to fulfil.”11 This duty to protect human rights includes the duty to protect against abuses by third parties, which includes businesses.12 With this in mind, States have a positive obligation to protect against human rights abuses by private actors occurring within their territories under international treaty law. International standards addressing business and human rights have affirmed and reinforced these treaty obligations. The UN Guiding Principles on Business and Human Rights,13 which were adopted by the UN Human Rights Council on 16 June 2011, reiterate the States’ duty to protect against human rights abuses by business enterprises in Principle 1.14 This Principle “requires [States] taking 8 UN Human Rights Committee, Concluding Observations: Republic of Korea, UN Doc. CCPR/C/KOR/CO.4 (October 2015). 9 UN General Assembly, International Covenant on Economic, Social and Cultural Rights, 16 December 1966, United Nations, Treaty Series, vol. 993. 10 UN Committee on Economic, Social and Cultural rights, General Comment 12: The right to adequate food (Article 11), UN Doc E/C.12/1999/5, 12 May 1999, para 15; UN Committee on Economic, Social and Cultural Rights, General Comment 15: The right to water (articles 11 and 12), UN Doc E/C.12/2002/11, 20 January 2003, paras 23–24. 11 UN Committee on Economic, Social and Cultural rights, General Comment 12: The right to adequate food (Article 11), UN Doc E/C.12/1999/5, 12 May 1999, para 15. 12 UN Committee on Economic, Social and Cultural Rights, General Comment 15: The right to water (articles 11 and 12), UN Doc E/C.12/2002/11, 20 January 2003, paras 23–24. 13 Human Rights Council, Guiding Principles on Business and Human Rights: Implementing the United Nations “Protect, Respect and Remedy” Framework, 2011. 14 Id. 4