Governance and Participant Engagement RECOMMENDATION 1 PRIORITY: HIGHER Enforce participant commitments. The Tech Coalition has developed a set of commitments for the participants of the Lantern Program (see Section 4.3), and it is important that these commitments are enforced. While commitments #1 (alignment with eligibility requirements), #3 (challenging external involvement), #4 (transparency), and #5 (compliance with privacy laws) are easier to enforce, some aspects of commitment #2 (quality assurance) may be dif昀椀cult to enforce (e.g., participants may not be manually reviewing signals before actioning them, contradicting the guidance provided by the Tech Coalition). In order to enforce compliance with commitments, the Tech Coalition should ensure that all participant commitments and guidelines are included in the Lantern Program agreement. In addition to the agreement, the Tech Coalition should also put in place mechanisms to help increase the likelihood that participants comply with the commitments of the program. This could include: › Mandatory training: As part of the onboarding process, the Tech Coalition should conduct training for (1) the primary point of contact at each participating company and (2) the content moderators who will engage with the Lantern database. The training would teach Lantern database users how they should handle signals and describe the potential risks of not handling them according to program guidelines. Access to the Lantern database should only be allowed for individuals who have completed this training. › Regular check-ins: The Tech Coalition should organize regular (e.g., quarterly) check-in meetings with each participant to understand how they are using the database and handling the signals. These meetings would also help surface learnings and best practices, which can then be shared with the broader group of participants. Some of the other recommendations listed below (e.g., recommendation #14 on quality assurance, #15 on high signal thresholds) can also help enforce participant commitments. Implementing this recommendation: This recommendation would be implemented by the Tech Coalition in collaboration with participating companies. RATIONALE › Principle 19 of the UNGPs states that where a company has leverage to prevent or mitigate adverse impacts, it should exercise it; and where a company lacks leverage, it should seek ways to increase it—for example, by offering capacity-building or other incentives to the related entity, or by collaborating with other actors. › Principle 16 of the UNGPs states that human rights policy should be “supported by any necessary training for personnel in relevant business functions.” BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 48