Key Points for Implementation Recs  Adopt a policy commitment to respecting human rights, and ensure it is embedded across the company and widely communicated to stakeholders. Such a public commitment is important because it demonstrates that top management consider respect for human rights as a minimum standard to conduct business with legitimacy. A few Myanmar companies have begun to adopt human rights commitments and publicly report on implementation. 1 Such commitments signal to local stakeholders a break with the past. To international business partners they signal an awareness of, and commitment to, operating in accordance with international standards. • Ensure other operational policies and processes are aligned with the human rights commitment, for example, clear and accessible privacy policies that explain the company’s policy on protection and its use or sale of customer’s data. For ICT companies that interact directly with users or customers, the company's Terms of Service, "user community" guidelines or similar documents, should explain the use of the company’s services in clear and accessible language, including in Burmese and other local languages.  Carry out human rights due diligence on an on-going basis: • Assess the risks and impacts the company and the other companies in its value chain (suppliers, contractors, etc) could pose to people and their human rights. − Take account of local complexities and legacies, including the considerable gaps in the existing legal framework identified in the Recommendations to the Myanmar Government, numbers 2 and 3 (and throughout this SWIA). Seek to fill those gaps by operating according to international standards. Take account of conflict dynamics when operating in areas of latent, existing and potential armed conflict. − Explicitly consider risks of contributing to or being directly linked to Government or business partners’ actions that may violate human rights. This should go beyond simply ensuring that business partners are not, nor have been, on the US or other sanctions list. Given the past involvement of some businesses in government or military related human rights abuses, careful due diligence is necessary including around the company’s commitment to responsible business practice, transparency and international standards. • Use the assessment of potential risks to identify and implement steps to prevent or at least mitigate those risks. The types of actions will vary considerably. It might include taking collective action to work with the Government to address gaps in the laws (see Recommendation 5 below), or specific actions in conflict-affected areas. See Recommendation 3 below on the wide range of risks and suggested responses highlighted in the SWIA. • Track responses to identified risks and impacts. Consider how workers, communities, users, customers and others potentially affected by company operations can be involved in monitoring activities. • Communicate publicly about what the company is doing to address the human rights impacts raised in this SWIA and more broadly, particularly when concerns 1 Pwint Thit Sa/Transparency in Myanmar Enterprises Report (2015) is intended to encourage increased transparency by Myanmar businesses by rating them based on information they publish on the internet in the areas of anti-corruption, organisational transparency, and human rights, health, safety and the environment. 24 PAGE RECOMMENDATIONS TO ICT COMPANIES