This paper builds on the requirements for sound due diligence as explained in the Thun Group of Banks' 2013 Discussion Paper (...) focuses on situations where banks may be directly linked to negative human rights impacts under UNGP 13b of the UNGPs (...) introduces the concepts of proximity to an impact (ranging from a low to high level of proximity) , which may , based on operational criteria , indicate the “degree of directness” of linkage between the impact and the product and service offered by the bank . Proximity thus describes a bank’s connection to an impact depending on the characteristics of the financial product and service provided. It is therefore an operational criter ion and must not be confused with leverage . It is also not a description of a spatial or geographic relationship between a bank and potential or actual adverse impacts. Unit of analysis, as a means to inform the focus of a bank ’ s due diligence (for example , by reference to the client (company or subsidiary) to which the financial product and service is offered, or asset in the case of specific asset finance)...