Country Analyses Kenya Extent and Quality of Labour Stakeholder Consulta­tion and Input During NAP BHR Development The Kenyan government aimed for a multistakeholder ap­proach when it developed its NAP BHR. The government’s commitment to a multistakeholder approach involved the inclusion of organised labour in consultations for the NAP BHR development. The Kenyan NAP BHR development process was led by the Department of Justice under the At­torney General’s Office, in collaboration with the Kenya National Commission on Human Rights and the NGO Ken­ya Human Rights Commission, and the Ministry of Labour and Social Protection was part of the steering committee. The Kenyan Central Organization of Trade Unions(COTU) was one of the members of the steering committee repre­senting trade unions’ voices. In the first step of the development process, the national steering committee(NSC) established to lead the process commissioned a national baseline assessment(NBA) to evaluate the implementation status of the UNGPs and rele­vant BHR frameworks. This was augmented by the Kenya Human Rights and Business Country Guide, a compilation of publicly available information from international institu­tions, local NGOs, government agencies, businesses, me­dia, and universities, aiming to provide a comprehensive overview of how businesses do or may impact human rights in a local context. The NBA was followed by policy dialogue forums held in Nairobi in October 2016 with stakeholders from the govern ­ment, businesses, and civil society organisations(CSOs). Following the Kenyan NAP BHR, between November 2016 and February 2018, regional stakeholder consultations were held in different parts of the country. In each region, those consulted included officials in the national and county gov­ernment, business representatives, local CSOs, and com­munity members impacted by business operations in their respective localities. Additional consultations encompassed a national forum with Indigenous people groups. There was due regard for the gendered impacts of businesses during the consultations, an examination of each theme, and in-policy action formulation. In this statement, organised labour groups were not men­tioned as a stand-alone stakeholder. However, in inter­views, it was mentioned that trade unions were invited to these consultations and their inputs were collected for the NAP BHR development. For example, the COTU participat­ed in these consultations as part of the NAP BHR steering committee. Similarly, some interviewees mentioned that the Federation of Kenyan Employers, the Kenya Associa­tion of Manufacturers, and the National Commerce of Ken­ya participated in the NAP BHR consultations. Some or­ganised labour groups also participated in the regional multistakeholder consultation forums organised to collect input for the NAP BHR. 24 As a result of these consultations and recommendations from the NBA, five priority thematic areas were identified by the Kenyan NAP BHR: land and natural resources, reve­nue transparency, environmental protection, labour rights, and access to remedy. Therefore, the extent of labour stakeholder participation and contributions to the NAP BHR development can be assessed as high given their rep­resentation at the highest governance body—the NSC. Be­ing the main umbrella body of trade unions in Kenya, COTU represented Kenyan workers’ interests on the NSC. It relied upon its countrywide branches to provide outreach on the NAP BHR development process and consolidated the views of constituent trade unions and mobilised their participation at the regional consultations. Moreover, the Kenyan NAP BHR development structure established an in­dependent Labour Rights Thematic Working Group that benefited from the participation of COTU and its affiliate trade unions. Extent and Quality of Gender Stakeholder Consulta­tion and Input During NAP BHR Development In Kenya, gender groups were actively consulted and repre­sented during the NAP BHR development process. Kenya also conducted an initial mapping of rights-holders and other stakeholders to participate in the NAP BHR process. Based on this mapping, women were identified as the most vulnerable group to the human rights impacts of business­es. As such, additional specific thematic consultations were organised for these special interest groups to ensure that their interests and issues were well captured in the NAP BHR. According to a case study on the lessons learnt from the Kenya NAP BHR development process,“Among the special interest groups that were most actively represented in the discussions of thematic working groups were Indige­nous communities, workers, businesses, and women.” 24 The following are a list of organised labour groups and the county’s consultation they participated in: Kitui – Kenya Union of Domestic, Hotels, Educational Institutions, Hospitals and Allied Workers(KUDHEIHA) and Kenya Union of Commercial Food and Allied Workers; Kakamega and Kisumu – Kenya National Union of Teachers; Kiambu (Thika) and Garissa Counties – Kenya Chemical Workers Union, Kenya Plantation and Allied Workers Union, KUDHEIHA, Kenya National Union of Teachers, and Security Work­ers Union; Turkana County – Teachers Association of Lodwar; and Mombasa and Kwale Counties – KUDHEIHA. 14 Friedrich-Ebert-Stiftung e.V.