4 4.8 Myanmar Good Practice Examples:  One company has reported that their Code of Conduct covers human rights and also has a Myanmar-specific statement on human rights due diligence requirements. They have established a community outreach program with State Liaison Officers to act as a link between ethnic groups and the company, and a local hotline to which people may report grievances related to sustainability issues. 592 C. Groups At Risk: Recommendations for ICT Companies Understanding and Addressing Differentiated Impacts of Projects     Understand the Myanmar context: Myanmar has a very diverse population in a complex and often conflict-ridden environment. Myanmar legal standards often fall below international legal standards to protect groups at risk. The groups at risk are often (at best) neglected parts of the population and at worst, subject to persecution by the Government or others. In these situations, in addition to international guidance on engagement and employment or contractual arrangements with groups at risk, experts on the specific vulnerable group in question should be consulted. Identify and engage: A first step in understanding what potential impact a project or services may have on groups at risk is to identify which vulnerable groups may be in the potential workforce and surrounding community as part of the company’s due diligence process. The ICT value chain is spread across the country and their workers and stakeholders will vary in different locations. This assessment may require additional specialist sociological or anthropological expertise and methods to identify, locate and engage individuals or groups at risk of abuse and marginalisation. Engagement may often need to be done separately, and sometimes discretely. Ensure assessments and prevention are differentiated: The objective of an assessment is to better understand how impacts may affect each potential group at risk, and in particular, to understand who could experience adverse impacts from the proposed project or service more severely than others. Disaggregated data and community consultations/focus groups will be needed to identify, assess and discuss potential impacts. Differentiated prevention or mitigation measures may be required to address the greater severity of impacts. Monitoring should track impacts on individuals or groups on a disaggregated basis. • Groups at risk should also be able to benefit from ICT sector equally with others. This too may require distinct measures. For example, if job training is offered, there may be a need for specialised or separate training provided for individuals from groups at risk who face exclusion from the dominant group, e.g. people living with disabilities. Consider the potential exposure of users at risk: As noted elsewhere (See in particular Chapter 4.1 on Freedom of Expression and Chapter 4.4 on Surveillance and Chapter 4.2 on Hate Speech), some of those groups highlighted in this Chapter are subject to specific risks within Myanmar. ICT companies who provide services for or affecting these groups (such as by hosting online content) should consider these vulnerabilities in advance of offering services. They should consider what steps can be taken to modify policies, procedures or services to avoid or minimise negative impacts on them, which might derive from hate speech, bullying or unlawful surveillance. 592 See further: Telenor, “Response by Telenor: Myanmar Foreign Investment Tracking Project", Business & Human Rights Resource Centre (last accessed September 2015). 234 PAGE CHAPTER 4.8: GROUPS AT RISK