Tech company responses and the UNGP ARTICLE 19 authoritarian contexts and adopting risk management strategies in response. Some companies have provided next to no information about particular human rights controversies. Bing has disclosed very little information about how it responds to Chinese censorship demands, for example. In Myanmar, beyond initial public announcements about actions taken to ban military accounts, most companies have not released detailed updates about how they are responding to ongoing military-inspired harmful speech on their platforms. Lack of country-specific human rights due diligence Third, tech companies should engage in regular, country-specific human rights due diligence. The case studies in this report show that there is little evidence that such due diligence is being undertaken. As outlined in the UNGPs, this should be an ongoing exercise with multiple steps, including identifying and assessing impacts, acting to prevent and mitigate risks, tracking the effectiveness of risk mitigation, and appropriate communication of performance.231 Most tech companies covered in this report do not appear to be engaged in ongoing human rights due diligence specific to China, Vietnam, or Myanmar, or at least they do not publicise it. Even where companies have engaged in due diligence, it has not been sufficiently comprehensive and ongoing. Telenor commissioned a human rights impact assessment before it entered Myanmar in 2014 but seemingly failed to maintain adequate ongoing assessments, including advanced planning for a responsible exit.232 An example of a flawed approach to human rights impact assessments in the region is given in the box below. Overall, tech companies operating in authoritarian countries in Asia need to devote much more leadership, planning, and resources to human rights due diligence. ____________________________________________ 231 B-Tech, Taking Action to Address Human Rights: Risks Related to End-Use, OHCHR, September 2020, p. 2 (providing a graphical summary). 232 Telenor, Human Rights in Myanmar. Telenor Myanmar did release annual ‘sustainability briefings’. 55