The Global Network Initiative (GNI) welcomes efforts by companies to increase transparency around human rights due diligence (HRDD) and human rights impact assessments (HRIAs). As part of companies’ HRDD processes, the use of HRIAs assists companies in identifying, preventing, and mitigating human rights risks and meeting their responsibility to respect human rights under the UN Guiding Principles on Business and Human Rights and the GNI Principles on Freedom of Expression and Privacy. The GNI Principles call on member companies to “identify circumstances where freedom of expression and privacy may be jeopardized or advanced and integrate these Principles into their decision making in these circumstances.” These assessments may be conducted by internal teams or in collaboration with external experts. Over the past decade, GNI member companies have pioneered the use of HRIAs to implement this principle.
The importance of communicating the results of HRDD and HRIAs publicly was highlighted at GNI’s 2019 Annual Learning Forum, although the most effective form of transparency will depend in part on the circumstances. Examples of increased transparency include:
- Facebook’s publication of the findings from — and their responses to —country-level impact assessments for Cambodia by BSR, and Indonesia and Sri Lanka by Article One;
- Telia Company’s publication of BSR’s HRIAs for subsidiaries in Lithuania and Sweden, as well as a summary of reports for the Eurasia region;
- Google’s publication of a summary of BSR’s human rights assessment for their celebrity recognition application program interface;
- Nokia’s publication of anonymized results from HRDD in their annual sustainability reports; and
- Verizon Media’s explanation of their approach to conducting HRIAs.
GNI’s latest public report further documents evolving HRDD practices in the technology sector. The independent assessments of 11 GNI companies show how companies are using impact assessments to fulfill their commitments to freedom of expression and privacy. As the report states:
“Given the dynamic nature of the ICT sector — both in terms of the underlying technologies and uses, as well as the regulatory environment — HRDD and HRIAs must be designed to account for constant change. The assessments show that companies are evolving their approaches by integrating impact assessment into wider due diligence systems, which vary from company to company, and even within companies, with regard to products, markets, and other topics and types of risks.”
Company efforts toward greater transparency regarding their HRDD and HRIAs are part of GNI’s shared learning agenda. We will continue considering how companies can integrate the GNI Principles into their business operations, ways to enhance and expand training efforts inside companies, and developing tools and guidance on topics such as HRDD and impact assessments.