re昀氀ects such an impact and that is accessible to its intended audiences. The business should provide suf昀椀cient information to evaluate the adequacy of its responses. Such communication should not pose risks to affected stakeholders, personnel, or to legitimate requirements of commercial con昀椀dentiality.” RECOMMENDATION 8 PRIORITY: MEDIUM Facilitate an annual dialogue with key stakeholders where participants can share and discuss their use of the Lantern Program. In addition to the transparency reporting that the Tech Coalition is planning for the Lantern Program, it is important for the participants to also be transparent about their participation in the Lantern Program and their use of the database. Requiring transparency by participants is (1) a natural extension of emphasizing that each company makes its own decisions on the basis of information received, and (2) an additional mechanism to assure compliance with the multiparty agreement. BSR recommends that participants of the Lantern Program take part in an annual dialogue with select and informed stakeholders to discuss their use of the signal sharing program, as well as share any insights and lessons learned. We believe this would facilitate a candid and open dialogue with informed stakeholders and serve the twin goals of facilitating accountability and strengthening the effectiveness of the Lantern Program. Implementing this recommendation: This recommendation would be implemented by the Tech Coalition in collaboration with participating companies. RATIONALE › Principle 20 of the UNGPs states that “to verify whether adverse human rights impacts are being addressed, business enterprises should track the effectiveness of their response. Tracking should: (a) Be based on appropriate qualitative and quantitative indicators; (b) Draw on feedback from both internal and external sources, including affected stakeholders.” › Principle 18 of the UNGPs states that human rights assessment should “involve meaningful consultation with potentially affected groups and other relevant stakeholders.” › Principle 1 of the CRBPs states that companies should “monitor and track the effectiveness of the business’s responses in order to verify whether an adverse impact on children’s rights is being addressed, using appropriate qualitative and quantitative indicators and drawing on feedback from internal and external sources, including affected children, families, and other stakeholders.” RECOMMENDATION 9 PRIORITY: HIGHER Establish a strategy for ongoing stakeholder engagement. Engagement with affected stakeholders and other experts underpins a human rights-based approach; building strong feedback loops through stakeholder engagement while avoiding engagement fatigue will be an important balance to strike, particularly as the Tech Coalition launches the Lantern Program and scales usage to a wider group of participants. BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 54

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