C3. Internal implementation

Does the company have mechanisms in place to implement its commitment to freedom of expression and privacy?

1. The company provides employee training on freedom of expression and privacy issues.

2. The company maintains an employee whistleblower program.

Guidance: Indicators C1 and C2 focus on company leaders and decision-makers. This indicator seeks company disclosure about how the company also helps the rest of its employees understand the importance of freedom of expression and privacy. When staffers write code for a new product, review a request for user data, or answer customer questions about how to use a service, they act in ways that can directly affect people’s freedom of expression and privacy. We expect companies to disclose information about whether they provide training that informs employees of their role in respecting human rights and that provides employees with an outlet to voice concerns they have regarding human rights.

Evaluation: This indicator is scored using a checklist, meaning companies can only receive full credit if they disclose information about employee training on freedom of expression and privacy and they disclose the existence of a whistleblower program that encompasses these issues. Disclosure around employee training should specify that the training covers freedom of expression, privacy, or both.

Potential sources:

  • Company code of conduct
  • Employee handbook
  • Company organizational chart
  • Company CSR/sustainability report
  • Company blog posts

For more information, click here for a glossary of terms.

Overall Company Performance

Company Performance