Recs Key Points for Implementation     Proactively undertake ongoing and meaningful engagement with workers, their representatives, users and communities throughout the project lifecycle, including at early stages of activities and key operational moments where risks change, recognising that engagement is a new concept for many in Myanmar. For example, Myanmar labour law requires an employer with more than 30 workers to form a Workplace Coordinating Committee (2 representatives of workers, 2 representatives of employer) whether or not there is labour organisation (e.g. union) in the enterprise. This kind of joint committee provides the outlet for mutually beneficial joint monitoring of working conditions by workers and the enterprise. Provide basic information to users and customers about how to stay safe online by protecting personal data, and support digital literacy growth for users, including the need to manage their “digital footprint” across devices and services and reporting concerns. Proactively provide information in a variety of formats and understandable local language(s) on key issues that are of concern to the Myanmar public, such as the health and safety impacts of mobile phones and cell towers. Online consultation and communication is nascent in Myanmar, but webchats could be a form of communication with stakeholders who are increasingly expecting to access responses from companies via their Facebook pages. 4. Put in place mechanisms that can address concerns and grievances quickly and effectively. UN Guiding Principles on Business and Human Rights: Remedying Impacts 22. Where business enterprises identify that they have caused or contributed to adverse impacts, they should provide for or cooperate in their remediation through legitimate processes. UN Guiding Principles on Business and Human Rights: Effectiveness Criteria 31. In order to ensure their effectiveness, non-judicial grievance mechanisms, both State-based and nonState-based, should be: (a) Legitimate: enabling trust from the stakeholder groups for whose use they are intended, and being accountable for the fair conduct of grievance processes; (b) Accessible: being known to all stakeholder groups for whose use they are intended, and providing adequate assistance for those who may face particular barriers to access; (c) Predictable: providing a clear and known procedure with an indicative time frame for each stage, and clarity on the types of process and outcome available and means of monitoring implementation; (d) Equitable: seeking to ensure that aggrieved parties have reasonable access to sources of information, advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms; (e) Transparent: keeping parties to a grievance informed about its progress, and providing sufficient information about the mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake; (f) Rights-compatible: ensuring that outcomes and remedies accord with internationally recognised human rights; (g) A source of continuous learning: drawing on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harms; Operational-level mechanisms should also be: (h) Based on engagement and dialogue: consulting the stakeholder groups for whose use they are intended on their design and performance, and focusing on dialogue as the means to address and resolve grievances. There are few outlets in Myanmar for effective resolution of grievances either through judicial or non-judicial means. This makes company-based alternatives all the more important to ensure issues are identified early and addressed quickly before they 26 PAGE RECOMMENDATIONS TO ICT COMPANIES