BSR | Human Rights Impact Assessment: Facebook in Myanmar 42 7. Recommendations 7.1 GOVERNANCE OF HUMAN RIGHTS BSR believes that the implementation of recommendations arising from this assessment is far more important than the assessment itself. As Principle 19 of the UNGPs states, “to prevent and mitigate adverse human rights impacts, business enterprises should integrate the findings from their impact assessments across relevant internal functions and processes.” However, BSR also notes that the human rights issues covered in this Myanmar HRIA exist within a broader human rights context at Facebook, including similar impacts in other countries and other human rights issues relevant for the company, such as supply chain labor standards and nondiscrimination in the workplace. For this reason, we make the following recommendations relating to the overall governance of human rights at Facebook. Each recommendation is accompanied by an explanation based on the insights gained during this assessment and the expectations of the UNGPs and GNI commitments. Recommendation Create a stand-alone human rights policy. This stand-alone human rights policy should be the place where Facebook expresses a public commitment to the International Bill of Human Rights. Facebook would list the areas of biggest human rights risks and opportunity for the company, and reference relevant articles of the UDHR, ICCPR, and the ICESCR, as well as other relevant human rights treaties. This policy should detail the governance structure of human rights at Facebook and provide links to other relevant policies, such as the Community Standards, the Supply Chain Code of Conduct, and GNI commitments. Explanation Principle 14 of the UNGPs states that, as the basis for embedding their responsibility to respect human rights, companies should express their commitment through a statement of policy. A recent BSR survey found that 56 percent of the world’s largest 200 companies have stand-alone human rights policies, including 48 percent of U.S. companies. There is an increasingly common perspective (such as from the UN Special Rapporteur on Freedom of Expression) that the term “human rights” and key principles of international human rights law should be used as a framework for social media content policies, such as Facebook’s Community Standards; however, there is a counter view that the inclusion of inaccessible language would harm the effectiveness of Community Standards, which are written for an audience of 2 billion. BSR believes that the creation of a public standalone human rights policy—separate from, but linking to the Community Standards—would be an effective solution to this problem, especially if the Community Standards are conceptually consistent with the human rights policy. A single stand-alone policy would act as a “hook” for the engagement of functions across Facebook to integrate human rights into its operations. Deepen and formalize a leadership, governance, and accountability structure inside Facebook to oversee the company’s human rights strategy, approach, and milestones. BSR recommends that this structure makes full use of existing Facebook mechanisms, such as the Audit and Risk Oversight Committee of the Board, the Privacy Cross Functional Working Group, the Content Standards Forum, and the substantial roles played by Principle 19 of the UNGPs states that effective integration of human rights requires that (1) responsibility for addressing such impacts is assigned to the appropriate level and function within the business enterprise, and (2) internal decision-making, budget allocations, and oversight processes enable effective responses to such impacts. Principle 20 of the UNGPs, which states that “in order to verify whether adverse human rights impacts are