The Thun Group’s recent and second contribution to the banks and human rights debate raises more questions than it answers...Though it might be said that [this paper] is more reflective than its predecessor, it appears to have taken the banks’ thinking backwards rather than forwards. At the root of this thinking lie the intertwined notions of ‘proximity’ and ‘directness’. That is specifically, the proximity of a bank to a human rights impact will be determined by the directness of its actions in effecting that impact. It is, according to the Thun Group, only when the bank’s actions are sufficiently direct that any responsibility or liability will be borne by the bank...It does seem odd, for example, for the banking sector to seek to restrict the reach of its power and responsibilities in respect of human rights outcomes, at the very time when other sectors - notably retail - are yielding to pressure to delve deeper into their supply chains to identify and address abusive practices.