[The] oversight mechanism for the International Code of Conduct...is a voluntary arrangement...But the inclusion of key government clients...could create strong incentives for industry participation, if in time those governments make participation in the ICoC system a precondition for access to government contractors...It is possible...that over time certification with the Code will become a market norm. Code certification will...raise the credibility of a private security company...[I]n return for this increased legitimacy and access to expertise, companies commit to cooperate with a system of reporting, independent field monitoring and...complaints. The price of increased legitimacy is increased accountability. The field monitoring scheme will focus on situations that pose the greatest human rights risk, and will operate according to established human rights methodologies...[B]y using the ‘effective remedy’ test set out in the UN Guiding Principles on Business and Human Rights, the mechanism will align this industry with the best practice emerging in other global industries facing similar security and operational challenges...The new mechanism will not provide justice to victims of past private security company abuses...It could, though, bring accountability significantly closer for future victims.