In this context, the Tatmadaw and members of the Buddhist majority in Myanmar used Facebook to disseminate “news” to promote disinformation and hate speech about the Rohingya as part of an ethnic cleansing campaign. The incendiary nature of the disinformation promoted more engagement by members of the Buddhist majority, which inspired acts of violence to be committed against the Rohingya. Following the violence, Facebook commissioned the organisation Business for Social Responsibility to undertake a human rights impact assessment (“HRIA”) of the company’s presence in Myanmar. The report found that “the Facebook platform in Myanmar is being used by bad actors to spread hate speech, incite violence, and coordinate harm" and that "Facebook has become a useful platform for those seeking to incite violence and cause offline harm.”66 The HRIA also erroneously, and without any explanation, concluded that Facebook’s services were “linked” to human rights abuses in Myanmar, stating “itself does not cause or contribute to these risks via its own action – rather Facebook is directly linked to them via the actions of users on its platform that violate Facebook’s Community Standards.”67 This finding is unsubstantiated in the HRIA, and ignores Facebook’s actions and omissions that resulted in the human rights impact. For each of the rights violations it examined, the HRIA concluded that Facebook did not contribute to these violations but rather was “directly linked to them via the actions of users on its platform.” The Assessment contained no further analysis of the distinction between ‘contribution’ and ‘linkage.’ Indeed, the approach from the outset of the HRIA appeared to be that social media platforms cannot contribute to human rights impacts where those impacts occur as a result of content posted by users. The opening section of the report simply stated: “It is important to note that internet companies will often be linked to human rights impacts that they do not cause or contribute to. For example, internet companies may be linked to hate speech, child sexual abuse material, and hacking that takes place over their platforms, even though they do not cause or contribute to these adverse human rights impacts themselves. When a company is linked to human rights impacts, the UNGPs expect companies to take action, though the nature of the action will be very different than had the company caused or contributed to these impacts.” 68 The HRIA thus oversimplified the situation by collapsing ‘contribution’ into causation. Clearly, an MNE can contribute to an impact which it does not cause. The threshold for contribution must therefore be lower than that for causation. The OECD Due Diligence Guidance for Responsible Business Conduct, which explains aspects of the Guidelines, provides helpful clarity on this point.69 The OECD explains that: An enterprise “contributes to” an impact if its activities, in combination with the activities of other entities cause the impact, or if the activities of the enterprise cause, facilitate or incentivise another entity to cause an adverse impact. 66 Business For Social Responsibility (October 2018) ‘Human Rights Impact Assessment’, <https://fbnewsroomus.files.wordpress.com/2018/11/bsr-facebook-myanmar-hria_final.pdf.>. [viewed 30 June 2021] 67 ‘Human Rights Impact Assessment’, p 35, <https://fbnewsroomus.files.wordpress.com/2018/11/bsr-facebookmyanmar-hria_final.pdf.>. [viewed 30 June 2021] 68 Ibid., p 7. 69 OECD Due Diligence Guidance for Responsible Business Conduct, Q29. 15