Extent of the Positive Impact of the NAP BHR on Policy, Legislation, International Convention Ratifi­cation, and Behavioural Change by Corporate Actors Even though the Kenyan NAP BHR proposes clear legisla­tions for enactment and amendments(e.g. the Companies Act 2015, Access to Information Act 2016, and credible op ­erational-level grievance mechanisms), 25 there do not seem to be many policy and legal changes to show as outcomes of the NAP BHR development. However, the Kenya NAP BHR has clearly helped embed labour rights within the BHR discourse in the country, elevating state and corporate responsibilities. According to the Kenyan National Human Rights Commission, it has also furthered commitments to bolster regulatory oversight(labour inspection, recruitment oversight, enforcement) of labour practices. For business owners, the NAP BHR has strengthened the expectation that businesses conduct HRDD in their operations, particu­larly as they affect workers, and improved the architecture for access to remedy for labour-related human rights viola­tions, signalling stronger institutional support. Moreover, the NAP BHR has brought more focus on mar­ginalised workers and gender issues within labour rights for business operations. In terms of policy changes, according to the Kenyan Office of the Attorney General, Department of Justice, the NAP BHR has contributed to the revision of the procurement document to include human rights com­pliance as a requirement for consideration of government tenders. However, the actual enjoyment of labour rights by workers remains dependent on how effectively the commit­ments in the NAP BHR are implemented, especially in in­formal work, casual employment, and sectors with weak oversight. For the above reasons, this is assessed as medi­um. Uganda Extent and Quality of Labour Stakeholder Consulta­tion and Input During NAP BHR Development The Uganda NAP BHR development process involved ex­tensive consultations across Uganda, engaging over 600 participants from 99 districts in 11 subregions. These con ­sultations included dialogues with communities affected by business projects, persons with disabilities, women, old­er persons, and refugees, as well as specific meetings with the business community and women in the mining sector. Examining the extent to which organised labour was in­volved in the consultation processes for the Ugandan NAP BHR, the evidence suggests some inclusion of labour/trade union actors but also gaps in the clarity and depth of their participation. According to the Ugandan NAP BHR, during the stakeholder consultations(March–October 2019), 11 re ­gional consultations were held, and“additional consulta­tions … with the business community(including business actors and trade unions) in Kampala” took place. The National Baseline Assessment and the situation analy­sis, including output from the regional consultation, identi­fied labour-rights issues(e.g., the casualisation of labour, poor remuneration, informal work, the absence of formal contracts) as a priority thematic area for the NAP BHR. Ac­cording to one study on gender in NAPs BHR, trade unions are listed among recognised stakeholders for NAP BHR consultations in Uganda. Overall leadership in NAP BHR development was given to the Ministry of Gender, Labour and Social Development(MGLSD) due to the close align­ment of its mandate with BHR issues. Nevertheless, while trade unions are mentioned in the con­sultation list, the sources do not provide detailed informa­tion on which unions took part, the depth of their partici­pation(e.g., Were they able to shape the agenda? Did they represent grassroots labour concerns?), or whether infor­mal-sector worker organisations were included. The consul­tations appear to have been broad and multistakeholder (communities, business actors, civil society) rather than specifically labour-organisation-led dialogues. Thus, while labour issues were covered, the labour constituency may not have had a dedicated stream or structured representa­tion at the consultations. The NAP BHR preparatory docu­ments emphasised consultations with“business actors and trade unions” in Kampala, but this suggests a primarily capital-level engagement rather than necessarily strong re­gional or grassroots trade union participation. Similarly, there is limited publicly accessible information on whether organised labour actors were integrated into the technical working committee that drafted the NAP BHR, or whether they were part of thematic working groups fo­cused on labour rights. The working committee member­ship list seems to emphasise government, civil society, and development partners and does not explicitly list labour unions. This is also substantiated by findings from inter­views with two representatives of trade unions in Uganda, who stated that they were not actively included in the con­sultation process for the NAP BHR:“The national action plan did not consider trade unions as a partner. Trade un­ions were not included in the committees involved.” 26 Therefore, it can be concluded that organised labour in Uganda was only included in the consultation process for the NAP BHR to a moderate level. Even though trade un­ion actors were explicitly invited and labour rights were identified as a thematic focus area, the extent of struc­tured, meaningful, and inclusive involvement of labour or­25 National action plan on business and human rights: For the implementation of the United Nations Guiding Principles on Business and Human Rights 2020–2025.(2020). Republic of Kenya. 26 The trade unions are the Uganda Building Construction Civil Engineering Cement and Allied Workers Union and Industrial Global Union, Women& Youth Representative (Uganda). Labour and Africa’s National Action Plans on Business and Human Rights 17