3.3 Determining Appropriate Action BSR’s HRIA methodology considers the appropriate action for a company to address adverse human rights impacts using factors contained in Principle 19 of the UNGPs: • Attribution—How closely would the Tech Coalition be connected to the human rights impact? BSR uses the following de昀椀nitions and “decision tree”: › Caused the impact—The Tech Coalition should take the necessary steps to cease or prevent the impact. › Contributed to the impact—The Tech Coalition should take the necessary steps to cease or prevent its contribution and use its leverage to mitigate any remaining impact to the greatest extent possible. › Directly linked to the impact through its products, services, or operations arising from its business relationships—The Tech Coalition should determine action based on factors such as the extent of leverage over the entity concerned and the severity of the abuse. • Leverage—How much ability would the Tech Coalition have to affect change in the wrongful practices of an entity that “causes” or “contributes to” the harm? How much ability does the Tech Coalition have to seek modi昀椀cation of or challenge the wrongful practice? How can the Tech Coalition increase leverage? Applying the “cause, contribute, directly linked” framework to platforms hosting user-generated content (UGC) is challenging due to the complex ways in which platforms interact with, enable, and amplify human behavior. ‘Cause-Contribute-Directly Linked’ Framework Cause the YES Will the Tech Coalition’s actions or omissions on their own be impact suf昀椀cient to result in the adverse impact? NO NO Not linked to Will the Tech Coalition’s products or services be involved in the harm? the impact YES Contribute to NO Are the Tech Coalition’s due diligence efforts, including efforts the impact to prevent or mitigate the impact, of suf昀椀cient quality? YES YES Will the Tech Coalition take actions (or fail to take actions) that NO Directly linked Contribute to encourage, facilitate, incentivize, motivate, or enable another to the impact the impact entity to cause an adverse impact? BSR TECH COALITION HUMAN RIGHTS IMPACT ASSESSMENT 16