72 complement. Having a grievance mechanism, however good, without wider stakeholder engagement processes, risks signalling to affected stakeholders that the enterprise wants to hear from them only when they have real problems. That said, the Guiding Principles also recognize that small or medium-sized enterprises may not need to engage directly with affected stakeholders if they have limited human rights risks and engagement is a genuine challenge for geographical, financial or other reasons. Such enterprises will look to other means of gathering information and perspectives about their potential human rights impact, as discussed under Guiding Principle 18. For these enterprises, having a simple but effective grievance mechanism can be one way of ensuring that they are still able to identify problems raised directly by those who may be affected. Q 77. When might an enterprise “participate in” a grievance mechanism rather than establish one itself? It will typically be appropriate for a large enterprise or one with significant human rights risks to have its own grievance mechanism. Small and mediumsized enterprises with limited human rights risks can also develop grievance mechanisms that are simple in form, yet able to meet the effectiveness criteria set out in Guiding Principle 31. However, enterprises may also consider participating in a grievance mechanism provided by an external organization, if it provides similar opportunities for the early identification and remedy of adverse impact. Examples include a hotline and remediation provided by an external organization—Government, business, NGO or multi-stakeholder—or a traditional mechanism run by the local communities or administration as part of their local practices. Such mechanisms should be reviewed to see whether they meet the effectiveness criteria and how any gaps could be addressed. Alternatively, an enterprise may establish its own mechanism but use external and shared resources to help reduce its costs and/or increase its capacity and effectiveness. Examples include enabling an NGO trusted by stakeholders to act as an access point and to engage with the enterprise in finding solutions to legitimate complaints. Such an NGO might take on this role for more than one enterprise, whether with independent funding or with pooled funding from the enterprises, provided this does not damage its credibility. Legitimate trade unions should play this kind of role with regard, at a minimum, to the workers