in the BSR report on Facebook’s Oversight Board, “one piece of content may not violate the Community Standards in isolation, it might result in significant adverse impact when taken in combination with a large volume of similar content and promoted via the News Feed algorithm.”82 Moreover, content removal does nothing to remedy the adverse human rights impacts suffered by the Rohingya, and to which Facebook contributed. The Oversight Board has no mandate to issue remedies in the form of rehabilitation or financial contribution. At present, the remedy which Facebook envisages only applies to Facebook’s users who have had a piece of content taken down. It does not envisage remedies for victims of human rights violations spurred on by hate-speech and disinformation disseminated across Facebook’s platform. 2.2.4. Facebook’s failure to provide for or co-operate in remediation Chapter IV. Human Rights (2): Enterprises should, within the context of their own activities avoid causing or contributing to adverse human rights impacts and address such impacts when it occurs. Chapter IV. Human Rights (6) Enterprises should provide for or co-operate through legitimate processes in the remediation of adverse human rights impacts where they identify that they have caused or contributed to these impacts. The OECD Due Diligence Guidance for Responsible Business Conduct recommends that the type of remedy or combination of remedy that is appropriate will depend on the nature and extent of the adverse impact and may include apologies, restitution or rehabilitation, such as inter alia the establishment of compensation funds for victims and educational programmes.83 The appropriateness of educational facilities as a remedy was considered in the Aloeboetoe case at the Inter-American Court of Human Rights, where the facts concerned members of Suriname’s armed forces killing seven persons associated with a village.84 The Court ordered the reopening and staffing of the village’s school and medical dispensary, in addition to monetary compensation for pecuniary and non-pecuniary damages. The Court justified this decision with the argument that although compensation was in part to secure education for the victim’s minor children, this was impossible without having an adequate infrastructure available to offer the desired education.85 The court further held that the State had failed to provide village with basic education services.86 This case demonstrates the appropriateness of education facilities as remedies that are both rehabilitative and restitutive. Despite Facebook’s actions and omissions, it has not taken any meaningful steps to remediate the harms to which it contributed. Representatives of the Rohingya groups who sent the open letter to the human rights chief at Facebook, Miranda Sissons, in June last year had a phone call with her in August, in which they explained that one of the most difficult aspects of their 82 Business For Social Responsibility (December 2019) 'Human Rights Review: Facebook Oversight Board” <h https://www.bsr.org/reports/BSR_Facebook_Oversight_Board.pdf.>. [viewed 11 October 2021], p 20. 83 OECD Due Diligence Guidance for Responsible Business Conduct, p34. 84 Aloeboetoe et al v Suriname, Inter-American Court of Human Rights, Judgment of September 10 1993, paras 5, 82, <https://www.corteidh.or.cr/docs/casos/articulos/seriec_15_ing.pdf>. [accessed 1 July 2021] 85 Ibid., paras 81-96. 86 Ibid., paras 8, 81-85, 96. 19