(although some, like the 昀椀nancial services industry, are more advanced than other non-tech indus- tries); it should not be assumed that these industries have the same cautious instincts that existing members of the Tech Coalition have. Therefore, in case of expansion into non-tech industries, a key role for the Tech Coalition would be capacity-building to ensure the responsible integration of these other industries into the child protection ecosystem. Speci昀椀cally, the Tech Coalition can consider putting in place a special onboarding and mentoring system for “non-tech” participants. Implementing this recommendation: This recommendation would be implemented by the Tech Coalition. 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 17 of the UNGPs states that due diligence “should be initiated as early as possible in the development of a new activity or relationship,” while Principle 18 states that human rights assessment should be undertaken “prior to a new activity or relationship; prior to major decisions or changes in the operation (e.g., market entry, product launch, policy change, or wider changes to the business); in response to or anticipation of changes in the operating environment (e.g., rising social tensions).” Transparency and Stakeholder Engagement RECOMMENDATION 7 PRIORITY: HIGHER Enhance the Lantern Program’s approach to transparency. The Tech Coalition’s transparency approach for the Lantern Program should be geared toward enabling stakeholders to understand how the program is being used and whether it is achieving its stated goals. Transparency reporting should provide information that is suf昀椀cient to evaluate the adequacy of the Tech Coalition’s approach while not posing risks to stakeholders or to the success of the Lantern Program. The Tech Coalition is planning regular transparency reporting around the Lantern Program. In addition to the metrics and narratives that are in the existing Transparency Template, BSR recommends including information about the following aspects of the program: › Standards for the inclusion of signals: A description of thresholds and criteria that participants use when evaluating which signals to upload to the database. BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 52