For these smaller companies with resource constraints, the Tech Coalition can consider offering additional support, such as designating a Tech Coalition staff member who would provide quality assurance and integration support to smaller companies in their 昀椀rst year of participation in the Lantern Program. 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 16 of the UNGPs states that human rights policy should be “supported by any necessary training for personnel in relevant business functions.” RECOMMENDATION 4 PRIORITY: HIGHER Establish a human rights policy and assign a human rights lead. Signal sharing is a new practice for most tech companies, and due to the sensitive nature of OCSEA, there are many questions that participants will need to deal with. The Tech Coalition can provide useful guidance on how to conduct signal sharing and how to handle gray areas, such as self-generated explicit imagery, and how to best provide educational resources to child users. There are a few different ways in which the Tech Coalition can provide guidance, including: › Create a user guide for signal sharing, including examples. › Hold of昀椀ce hours or optional one-on-one meetings with participants to answer questions, understand how they are using the program, identify best practices, etc. › Organize best practice sharing sessions for 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. BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 50