› Principle 19 of the UNGPs states that companies should “integrate the 昀椀ndings from their impact assessments across relevant internal functions and processes, and take appropriate action.” › The GNI Principles state that “If national laws, regulations and policies do not conform to international standards, ICT companies should avoid, minimize, or otherwise address the adverse impact of government demands, laws, or regulations, and seek ways to honor the principles of internationally recognized human rights to the greatest extent possible.” RECOMMENDATION 17 PRIORITY: MEDIUM Conduct ongoing human rights due diligence (HRDD). New human rights risks may emerge over time as participation in the Lantern Program increases, use of the Lantern database expands, and global regulatory frameworks for the prevention and detection of OCSEA evolve. The Tech Coalition should conduct ongoing human rights due diligence to identify and assess key developments that may indicate shifts in human rights risks or impacts of the Lantern Program over time. Due diligence should be conducted before key milestones and decision points, including the following: › Proliferation of new technologies that may impact user behavior on online platforms (e.g., generative AI technologies) › Proliferation of new OCSEA threats › Enactment of new OCSEA regulations › Expansion of the Lantern Program to new participants or industries › Expansion of the signal types included in the Lantern database Ongoing HRDD could include methods such as adversarial testing (i.e., exercises where the product or program is stress tested to discover the ways in which it might be misused, abused, or associated with harmful outcomes). Implementing this recommendation: This recommendation would be implemented by the Tech Coalition. RATIONALE › Principle 17 of the UNGPs states that “in order to identify, prevent, mitigate, and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence.” Further, Principle 17 of the UNGPs also states that human rights due diligence, “should be ongoing, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolve.” › Principle 1 of the CRBPs states that companies should conduct ongoing human rights due diligence “for assessing its actual and potential human rights impact, including on children’s BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 60